PROCEEDINGS OF A CONGRESSIOXAL
SEMINAR ON LOW-LEVEL IONIZING
A REPORT TRANSMITTED BY
THE SUBCOmilTTEE ON ENEKGY AND
INTERIOR AND INSULAR AFFAIRS
U.S. HOUSE OP REPRESENTATIVES
NOVEMBER 1976 >
Printed for the use of the
Committee on Interior and Insular Affairs
U.S. GOVERNMENT PRINTING OFFICE
WASHINGTON : 1976
COMMITTEE ON INTERIOR AND INSULAR AFFAIRS
House of Representatives
JAMES A. HALEY, Florida, Chairman
ROY A. TAYLOR, North Carolina
HAROLD T. JOHNSON, California
MORRIS K. UDALL, Arizona
PHILLIP BURTON, California
ROBERT W. KASTENMEIER, Wisconsin
PATSY T. MINK, Hawaii
LLOYD MEEDS, Washington
ABRAHAM KAZEN, Jr., Texas
ROBERT G. STEPHENS, Jr., Georgia
JOSEPH P. VIGORITO, Pennsylvania
JOHN MELCHER, Montana
TENO RONCALIO, Wyoming
JONATHAN B. BINGHAM, New York
JOHN F. SEIBERLING, Ohio
HAROLD RUNNELS, New Mexico
ANTONIO BORJA WON PAT, Guam
RON DE LUGO, Virgin Islands
BOB ECKHARDT, Texas
GOODLOE E. BYRON, Maryland
JAIME BENITEZ, Puerto Rico
JIM SANTINI, Nevada
PAUL E. TSONGAS, Massachusetts
ALLAN T. HOWE, Utah
JAMES WEAVER, Oregon
BOB CARR, Michigan
GEORGE MILLER, California
THEODORE M. (TED) RISENHOOVER,
JAMES J. FLORIO, New Jersey
JOE SKUBITZ, Kansas, Ranking Minority
SAM STEIGER, Arizona
DON H. CLAUSEN, California
PHILIP E. RUPPE, Michigan
MANUEL LUJAN, Jr., New Mexico
KEITH G. SEBELIUS, Kansas
ALAN STEELMAN, Texas
DON YOUNG, Alaska
ROBERT E. BAUMAN, Maryland
STEVEN D. SYMMS, Idaho
JAMES P. (JIM) JOHNSON, Colorado
ROBERT J. LAGOMARSINO, California
VIRGINIA SMITH, Nebraska
SHIRLEY N. PETTIS, California
Charles Conklin, Staff Director
Lee McElvain, General Counsel
Henry R. Myers, Special Consultant on Nuclear Energy Matters
Michael C. Marden, Minority Counsel
Subcommittee on Energy and the Environment
MORRIS K. UDALL, Arizona, Chairman
ALAN STEELMAN, Texas
JOE SKUBITZ, Kansas
SAM STEIGER, Arizona
MANUEL LUJAN, Jr., New Mexico
ROBERT E. BAUMAN, Maryland
STEVEN D. SYMMS, Idaho
JAIME BENITEZ, Puerto Rico
JONATHAN B. BINGHAM, New York
BOB CARR, Michigan
RON DE LUGO, Virgin Islands
BOB ECKHARDT, Texas
JOHN MELCHER, Montana
GEORGE MILLER, California
TENO RONCALIO, Wyoming
JOHN F. SEIBERLING, Ohio
PAUL E. TSONGAS, Massachusetts
JOSEPH P. VIGORITO, Pennsylvania
Stanley E. Scoville, Staff Counsel
Michael B. Metz, Minority Staff Counsel
Note. — The first listed minority member is counterpart to the subcommittee chairman.
Members of the Committee on Interior
and Insular Affairs
U.S. House of Representatives
Washington, D.C. 20515
As part of its nuclear oversight responsibility, the
Committee's Subcommittee on Energy and the Environment
has been concerned with health hazards associated
with nuclear radiation.
The Subcommittee chairman has sent to me a transcript
of a House Environmental Study Conference meeting at
which disparate views were presented with regard to
hazards arising from the presence of artificial radia-
tion sources. Since this is a subject of widespread
interest, I am making the transcript available to all
Members of the Committee.
JAMES A. HALCY. FLA.. CMAmMAN
ROeCNT G. STEPHENS .
JOSEPH P. VrOORITO. P/
JOHN MELCHER. MONT.
TEND RONCALIO. WYO.
COODLOE E. BY
PAUL E. TSONGAS. MAS!
I STEELMAN. TEX.
COMMITTEE ON INTERIOR AND INSULAR AFFAIRS
U.S. HOUSE OF REPRESENTATIVES
WASHINGTON, D.C. 20515
November 3, 1976
SHIRLEY N. rrrris. c»
James A. Haley, Chairman
Committee on Interior
and Insular Affairs
U.S. House of Representatives
Washington, D.C. 20515
Dear Mr. Chairman:
Transmitted herewith is the transcript of a symposium
organized by the House Environmental Study Conference for
the purpose of discussing the effects upon people of "low
level" ionizing radiation. People are exposed to such
radiation from both artificial and natural sources. Of
considerable concern is the extent to which radiation
produced by artificial sources is a hazard to human health.
This question has been a matter of public debate for more
than three decades. As the transcript makes clear, experts
remain in substantial disagreement with regard to the
nature of these risks.
Meetings such as those organized by the Environmental
Study Conference help to delineate the areas of agreement
and to indicate those aspects of the problem which deserve
additional research. While the Subcommittee on Energy and
the Environment was not involved in the organization of the
conference (and views presented therein do not necessarily
reflect views of Subcommittee members) I am forwarding the
meeting record because I believe it will be exceedingly useful
to both experts in the field and to non-experts who wish to
obtain a sense of the controversy.
Subcommittee on Energy and
I. Opening Statements by Sen. Gary Hart and Dr.
Karl Morgan 1
II. Low-Level Radiation, What Is It and VJhat Are
Its Major Sources? 7
III. Health Effects of Low-Level Radiation, What Are
They and When Do They Appear? 9
IV. Dose-Response Relationships, Linear or Non-Linear? . . 20
V. Protection of Special Groups 35
VI. Federal and State Responsibilities in Regulation,
Monitoring and Inspection 49
VII. Current Radiation Protection Standards, Responsibility,
and Scientific Basis 75
VIII. Health Effects of Radiation, Is the Data Base
Adequate for the Determination of Standards? What
Research Is Needed? 84
IX. Health Effects to Occupational and General Populations
Exposed to the Present Federal Standards 95
X. The Cost-Benefit Theory of Federal Radiation Standards,
Is It a Proper System? What Are Alternative Systems? 101
XI. Specific Recommendations for Congressional Hearings,
Legislation or Other Actions 109
Selected Bibliography on Effects of Low Dose Radiation
on Man 113
Glossary of Radiation Health Terms 125
Addition to the Testimony of Dr. Victor E. Archer, M.D.
from a Letter to Mr. Bruce Myles, April 1 , 1976 129
Addition to the Testimony of Dr. Edward S. Martell,
Unresolved Health Effects of Internal Alpha Emitters . . . .130
Recommendations Made to the Environmental Study Conference,
Submitted to the Record by Dr. Rosalie Bertell 133
Letter Submitted to the Record by Dr. Bernard Cohen 135
On May 4, 1976, a panel including scientists and public
health officials presented a wide spectrum of views on the health
effects of low-level ionizing radiation during a one-day conference
aimed at informing Congressional Members and their staffs on this
The conference was organized by the Environmental Study
Conference, at that time composed of a bipartisan group of 165
House Members, and the Environmental Policy institute, a non-
profit research center. The purpose of the meeting was to provide
insights into a question increasingly asked by the public: how
harmful to health, if at all, is the low-level ionizing radiation
from the nuclear fuel cycle, medical x-rays, and other artifical
Members of the House and Senate co-sponsoring this confer-
ence included Representatives Richard Ottinger, Gilbert Gude,
James Jeffords, and John Seiberling, and Senators Gary Hart,
Abraham Ribicoff, Edv/ard Brooke, and Jacob Javits.
The following pages contain a transcript of the meeting,
edited and reorganized by the Congressional Research Service.
Digitized by the Internet Archive
CONFERENCE ON LOW-LEVEL RADIATION
MAY 4, 1976
ENVIRONMENTAL STUDY CONFERENCE
Washington, D. C.
The Conference met, pursuant to notice, at 9:35 a.m, in room
1202, Dirksen Senate Office Building, Hon. Gary Hart presiding.
Present: Senator Hart (presiding).
Senator Hart. Ladies and gentlemen, I think we are prepared
to proceed with this discussion this morning. I am sorry that my
friend Dick Ottinger, Congressman from New York, will not be able
to be with us for the opening of today's conference. However, it
is my understanding that he will be in and out throughout the day,
hopefully rather frequently. It was primarily through the coor-
dination of the Environmental Study Conference, which Congressman
Ottinger chairs, that this forum was originally organized.
The conference today is the first Congressional effort in
several years to review the health effects of low-level ionizing
radiation from nuclear power facilities, medical and dental x-rays
and other sources.
The purpose of the conference is to provide a Congressional
forum for the discussion of recent research findings which indi-
cate the need for closer scrutiny of Federal programs designed
to protect the public from radiation exposure.
The conference is co-sponsored by the Environmental Study
Conference, a group of about 165 members of the House, Representa-
tives Ottinger, Gude, Jeffords, and Seiberling, and Senators
Ribicoff, Brooke, Javits and myself.
Our speakers represent a wide range of views on the health
effects of low-level radiation and the extent to which the pub-
lic and occupational subgroups are and will be protected from
low- level radiation.
The questions surrounding low-level ionizing radiation are
becoming increasingly salient as pressures mount for this nation
to turn to nuclear power as an answer to our energy shortage. As
this industry expands, many more citizens will be exposed to high-
er levels of radiation.
As we know, humanity has always been exposed to naturally oc-
curring background radiation. Dr. Gofman, the co-discoverer of
Plutonium, has estimated that this naturally occurring radiation
causes approximately 19,000 extra cancer deaths annually, and be-
tween 58,000 and 580,000 genetic deaths per year in this country
With these figures in mind, it seems almost unbelievable that
government policies could advocate the existence of artificially
produced radiation, with its consequent cost to human life. How-
ever, this has happened, and the average American is exposed to
almost twice the radiation that occurs naturally.
We can do little about background radiation, but we can, and
must, curb that radiation produced by man. Current regulations
permit exposures of 170mrem annually. A disturbing consequence
of every individual receiving this dose could amount to about
32,000 extra cancer and leukemia deaths every year, according to
Drs. Gofman and Tamplin.
As if this exposure were not enough, employees of nuclear in-
dustries are, in my mind, incredulously exempted from those regu-
lations. They can legally receive radiation at levels thirty
times that of the general population -- an exposure which has been
calculated to increase the risk of leukemia and cancer by 5 per-
cent every year, and to significantly lower life expectancy.
Our investigations today, however, should not limit itself
to the more glamourous issue of radiation from nuclear industries,
which amounts to only a small percentage of the total threat to
human health. Radiation from medical and dental x-rays accounts
for an estimated 3,000 deaths per year from various forms of can-
cer and genetic damage, according to the International Commission
on Radiological Protection. The Commission also estimates that we
may be introducing approximately 30,000 extra deaths into future
generations each year from genetic effects. The National Academy
of Science, the BEIR Committee, and the Medical X-ray Advisory
Committee all agree that radiation from diagnostic x-rays can be
significantly and easily reduced.
Federal regulations are intended to define the quantity of
exposure that the human body can safely accumulate. But since
any accumulation produces biological damage, these standards are
ultimately based on an arbitrary bureaucratic decision about how
many adverse health effects, a euphemism for deaths, we will put
up with -- the so-called "acceptable costs."
The hard questions are not being asked. My colleagues and I
have asked all of you to participate in this forum to address and
hopefully shed new light on these very important questions.
What are involved here are not mere statistics, but people
-- individual human lives. And it is ultimately these people, and
we as their elected representatives, who must make these hard
decisions. We must be sure that these decisions are based on the
facts, with full knowledge of the possible consequences. It is
the facts which must be aired in forums like this, and not con-
fined to the obscure publications of myriad Federal agencies.
I am confident, and I am sure my colleague. Congressman
Ottinger is confident, that this conference will mark an impor-
tant stage in the dialogue that must take place as pressures for
nuclear acceptance mount.
As for the time-table this morning, we will be meeting from
9:30 until just after 12:00 o'clock, taking a break for lunch and
continuing at 1:45 until approxiamtely 4:30, or until we have ex-
hausted the subjects at hand.
Chairing the conference will be Dr. Karl Morgan, Professor of
Health Physics at the Georgia Institute of Technology, one of the
pioneers in radiation protection.
I am now pleased to let Dr, Morgan introduce our panelists
and further explain the format.
Dr. Morgan. Good morning.
The panel consists of persons who are well-known in this
field and many of us have formulated opinions through the years.
I am thinking that perhaps I need a larger gavel here to cut
some of us off if we really get tangled up close in some of these
Beginning on my left, Mr. Taylor, I do not believe is here.
George Taylor is scheduled to be with us. He is the executive
secretary of AFL-CIO.
Dr. Frank Collins, consultant on occupational safety for
the Oil, Chemical and Atomic Workers on my left.
Dr. John T. Edsall, Professor Emeritus of Biology at Harvard
University, and Chairman of the VI International Conference of
Dr. Irwin Bross has been director of the biostatistics at
Roswell Park Memorial Institute for Cancer Research in Buffalo,
New York, for over 17 years.
Dr. Rosalie Bertell, research associate at the Roswell Park
Dr. Victor Archer, who is medical director of the U.S. Pub-
lic Health Services, National Institute for Occupational Safety
and Health, Salt Lake City, Utah.
Mr. Seymour Jablon, currently associate director with the
Medical Follow-up Agency of the National Research Council, Nation-
al Academy of Sciences and staff officer for the Radiation Effects
Research Foundation. He also served previously as Chief of the
Department of Epidemiology and Statistics of the Atomic Bomb Casu-
alty Commission and is a consultant to the BEIR Report Advisory
Dr. Edward Martell , now with the National Center for Atmos-
pheric Research, Boulder, Colorado and formerly attached to the
Strategic Air Command as an advisor on high altitude fall-out.
Dr. Victor Bond, associate director in life sciences at
Brookhaven National Laboratory, Upton, New York since 1967 and
formerly a member of the BEIR Report Advisory Committee.
Dr. Ernest Sternglass, Professor of Radiology at the Univer-
sity of Pittsburgh.
Leo Goodman is a consultant in atomic energy safety. He has
not arrived yet. (He arrived later.)
Dr. Charles Richmond is associate director of biomedical and
environmental sciences, Oak Ridge National Laboratory, Tennessee.
Dr. William Ellett, Criteria and Standards Division of the
Environmental Protection Agency, Office of Radiation Programs.
Dr. Bernard Shleien, Office of Medical Affairs of the Bureau
of Radiological Health, Food and Drug Administration. He pre-
viously spent 16 years with the Public Health Service's radiation
Dr. Mark Barnett, associate director of the Bureau of Radio-
logical Health's Division of Training and Medical Applications.
Dr. Roger Mattson, director of NRC's Division of Siting,
Health and Safeguards Standards.
Dr. Helen Caldicott, a pediatrician who for several years was
director of cystic fibrosis research at Adelaide Children's Hos-
pital, Adelaide, Australia and who is currently conducting clini-
cal research in cystic fibrosis at the Boston Clinic.
Dr. Bernard Cohen, director of the University of Pittsburgh's
Nuclear Physics Laboratory was not able to be with us. (Material
has been included in the Appendix.)
I do not see Dr. John Gofman. He is Professor Emeritus of
Biomedical Physics, University of California at Berkeley, and
Chairman of the Committee for Nuclear Responsibility. (Sickness
prevented his attendance. Material has been included in the Ap-
These are the panelists. Several have not yet arrived.
Hopefully they will be with us shortly.
I would now like to explain the procedures we are proposing
to follow. The purpose of this conference is to address the ques-
tion of low-levels of exposure to ionizing radiation, sources of
this exposure, measures to reduce and control this exposure, the
biological consequences of this exposure, the radiation protection
standards and their adequacy and research programs designed to
answer some of these questions.
The staff of the Environmental Study Confernece, of which
Congressman Ottinger is Chairman, has prepared a list of 17
questions which address this subject, and I am sure in answering
these questions, we will raise some new ones and that we will not
be expected to solve all of the issues or to provide answers to
the questions which will completely satisfy all of the proponents
and opponents of nuclear energy.
I hope, however. Senator Hart, we will clarify some of the
issues and enable members of Congress and their staff to better
understand the problems and what action, if any, should be taken
to bring about appropriate corrections.
We have a very tight schedule, and in order to stay on sche-
dule and finish by 5:00 o'clock this afternoon, I have been asked
to rigidly limit the time of each speaker to three minutes response
to any question, with the exception of question number 5, where we
will allow 5 minutes for each speaker.
I will read each question as we come to it, and call upon
members of the panel to respond in the order of their names as now
listed on our provisional agenda. Please stay within these time
limits, and at the close of the morning session and at the after-
noon session there will be fifteen minute periods for questions and
comments from the floor, and especially from members of Congress
and their staffs. And those of you in the audience, when you have
questions or responses, please state your name so that it can be
recorded on the record.
Mr. Myles has handed me a paper in which it has been requested
that a few definitions be given. While some of the audience is
assembling, maybe I can attempt a few quick definitions.
First of all LET, the linear energy transfer, in simple terms
(not as a college professor defines it), relates to the density of
ionization, to the number of ion pairs along the track, a linear
path, or a straight portion of the path of an ionizing particle.
To those of you with physics background, it is essentially the same
as stopping power or it relates to specific ionization.
It defines how thick the track of ions is. In the case of
alpha particles, as an example, in one centimeter of air, you
would probably have about ten thousand ion pairs along that track,
whereas for a beta particle or an electron you would have something
like a hundred ion pairs per centimeter of air.
For that reason the alpha particles, if they are given off in
living tissue, are much more harmful than the lower LET radiation
from beta and gamma radiation.
Then there was a question of what are daughter products. It
so happens for many of the radioactive materials, when they decay
radioactively , they decay into another radioactive daughter, may-
be a succession of daughters which are radioactive, decaying on
down until eventually you arrive at a stable product where the
half-life is very long.
Then there is the question about ionizing and nonionizing
radiation and why exclude nonionizing radiation from our discus-
sion. When I was approached to chair this meeting, that question
came to me immediately because it so happened, and I believe it is
true, that the risk of nonionizing radiation may be as great, if
not greater in some respects than those of ionizing radiation.
When we speak of ionizing radiation, we mean those radiations
that can tear loose the electrons from the atom with which they
are associated leaving a plus and minus charge, i.e. the positive
ion and the negative electron.
In the case of nonionizing radiation, you are talking about
some type of radiation that does not have enough energy per unit,
particle or photon, to bring about the separation of the electrons
from the atom. There you are speaking of something like visible
light, ultraviolet, microwave radiation, RF radiation, mechanical
radiation such as sonic, ultrasonic and infrasonic radiation.
Low-Level Radiation, What Is It and What Are
I ts Major Sources?
Dr. Morgan. We come now to the first question which has been
prepared by the staff, namely. What is low-level ionizing radia-
tion and what are the major sources about which we should be con-
I will attempt an answer to this question to lead off this
There is no agreed upon definition of low-level ionizing
radiation exposure. Rather than list all of the definitions and
take a weighted average, or be indecisive, I am going to be arbi-
trary and perhaps a bit dictatorial and define low-level radia-
tion exposure in the case of the radiation worker as that which is
likely to result in a dose that is equal to or less than the max-
imum permissible occupational dose values as recommended by the
National Council on Radiation Protection and Measurements and as
summarized in the NRCP Report No. 39, 1971.
Thus, low-level dose for the radiation worker will be taken
as the dose which is equal to or less than 75 rems per year to
the hands, 30 rems per year to the forearms, 5 rems per year to
the whole body, gonads, lenses of the eye and red bone marrow,
15 rems per year to all other body organs.
With this as the boundary conditions of occupational expo-
sure, and one-tenth of these values as limits for non-occupa-
tional exposure and 170 millirem per year as the maximum average
for the population as a whole, we can, in the discussion that
follows indicate whether or not these levels are satisfactory or
whether they should be changed.
I would like to express the opinion at the outset that these
levels are satisfactory only so long as they are considered as
upper limits that we strive not to reach, and when we operate un-
der the philosophy that we must avoid unnecessary exposure and
keep both occupational and non-occupational exposures as low as
practicable and as low as readily achievable.
The second part of the question is What are the major sources
of low-level exposure?
The answer is given in the BEIR report as of 1972 for the
average whole body exposure in the U.S. and the values are much
the same today, namely, natural background, about 100 millirem per
year; medical and dental, 73 millirem per year-, fall-out, 4 milli-
rem per year; occupational, about 0.8: nuclear power, 0.003 milli-
rem per year; and nuclear power extrapolated into the year 2,000,
less than 1 millirem per year.
Do any of the panelists which to add to this definition of
low-level exposure? (There was no response.)
Now, we will take this as the boundary condition of our de-
finition. By boundary, I mean low-level is defined as these val-
ues or any values less than these values, from zero up to these
Health Effects of Low-Level Radiation,
What Are They and When Do They Appear?
Dr. Morgan. We come to the second question that has been
suggested. We have not indicated names of those on the panel who
would like to respond, but I welcome you to do so. I will start
out with an attempted answer to the question -- What are the
health effects, known and suspected, of low-level ionizing radia-
tion? When do these effects show up?
My answer would be, present medical techniques are not suf-
ficiently sensitive to detect any immediate effects of these low-
level exposures. The consequence of low-level exposure is that
the person has a greater risk than otherwise of having a malig-
nancy, depending on the age of the person, sex, magnitude of dose,
type of radiation, body organ radiated, kind of malignancy and so
forth. The malignancy may manifest itself in one to two years,
or after, say 50 to 80 years, and in the vast majority of cases,
a cancer resulting from radiation exposure is indistinguishable
from one originating from other causes.
Some scientists believe that exposure to ionizing radiation
results in aging or life-shortening due to non-specific effects
and have suggested that life-shortening may be on the order of
10"^ life spans per rem. This would, in the case of a 70-year
human, correspond to Ih days life-shortening per rem exposure of
the total body.
I think from this we recognize that epidemiological studies
of very large populations exposed to these low-levels of radia-
tion for many years would have to be conducted in order to demon-
strate effects of low-level exposure. For example, on the BEIR
hypothesis, a thousand persons exposed to 5 rem per year, to the
total body, for thirty years, would be expected to result in only
an increase of about 15 cancers above normal and an average life-
shortening -- if there is a non-specific life-shortening -- of
each person of a little more than one year.
Would some panelists like to respond to this?
Dr. Bertell. I would just like to point out some of the
results hidden behind the hypothesis of life-shortening, which
I think is now a viable and testable hypothesis.
Life-shortening means that the person is vulnerable to the
diseases of aging at an earlier point. So I would like to in-
clude in our consideration of radiation effects such things as
diabetes mellitus, cardiovascular disease, stroke, hypertension
and even suicide, cataracts, a whole slew of things which we nor-
mally connect with aging.
Dr. Morgan. Thank you very much. Are there other comments?
Yes, Dr. Bross.
Dr. Bross. I would like to respond. I think the figures are
79-767 O - 76 - 2
somewhat obsolete. I think that the actual effects are substan-
tially larger. What has happened is, as we do more research we
find larger effects.
Years ago, Alice Stewa rti/ had found a 50 percent to 100 per-
cent increase in leukemia in the children whose mothers had x-rays
of the fetus during pregnancy. We found 50 percent when we first
analyzed the Tri-state survey which is the basic source of data
that we have been using. While this was large enough to confirm
the earlier reports, it did not convince the radiologists who had
not been previously convinced. However in 1970, the Department
of Biostatistics at Roswell, looked more closely at children who
were defined by their medical histories as "susceptibles . "1/ The
diseases in this included asthma, hives, eczema, allergy, pneu-
monia, dysentery and rheumatic fever.
In the susceptible children, we found a 500 percent increase
instead of a 50 percent increase. In our latest analyses, using
a procedure which is still more sensitive and gets down to the
persons who are actually affected by the radiation, we get a 5000
percent increase in leukemia.
What I think is that the previous analyses of the data have
not brought out the problem clearly. This whole matter needs to
I think the scientific evidence of cumulative genetic degra-
dation we are prepared to produce will indicate the need for sub-
stantial reduction in the currently permissible exposure levels.
Dr. Morgan. Thank you. Dr. Bross. Other comments? Dr.
Dr. Caldicott. I would just like to mention the genetic
effect on future generations. We can extrapolate from animal
experiments, but we know the human species is the most sensitive
species to radiation. We have already had radiation around, ar-
tificial radiation, for about 50 years. We know that background
radiation during the centuries has produced us because of survi-
val of the fittest, in that the mutations which have been good
have survived, the bad mutations have died. We know that the
majority of mutations occurring now are deleterious or bad, and
produce disease. We do not know the effects of low-level radia-
tion on the gonads, the testes and ovaries where the new gener-
ations are to be produced, because it will take many generations
to assess this damage, and by then it will be too late.
There are two forms of mutations or damage to genes and eggs
and sperm. One is dominant, which would be seen in the next
generation. One is recessive, and may be carried by people
through generation to generation, such as cystic fibrosis where
one in twenty of us carry this gene. This disease is a common
fatal disease of childhood. We all carry hundreds of such dele-
terious recessive mutations.
Much is unknown about the long term effect of radiation on
human beings. Time will provide the evidence, i.e., hundreds of
years; we will have to wait and see.
Dr. Morgan. Are there other comments? Mr. Jablon?
Mr. Jablon. I would just like to comment on some of the re-
marks that have been made.
The largest study that I know of involves essentially an un-
selected population, the studies of the survivors of Hiroshima
and Nagasaki. We have, of course, paid a great deal of attention
to the problem of trying to identify specific effects of rather
large doses, not small .
There has not been to date, and the studies have now been
going for thirty years, any evidence of cardiovascular disease
being affected by the acute doses.
The chronic effects have largely been in the area of cancer
Dr. Morgan. Dr. Bertell?
Dr. Bertell. I would like to respond to Mr. Jablon on the
Hiroshima data. I have looked at that quite carefully. What he
said was correct, but this is a sensitive point. He referred to
acute doses of radiation, which I believe are at least over 200
rad. I am interested, and I think this conference is interested,
in low-level effects; diabetes mellitus and cardiovascular disease
were significant at the lower levels.
There is a built-in assumption in the study on the Hiroshima
data, anything that shows up at a low level should show up worse
at a higher level. I think this is false to the biological pic-
You are dealing here, as far as I can see, with an overkill.
If the cells are destroyed, they are sloughed off from the body.
They do not continue to live within the body and produce misin-
formation and reproduce themselves within the body.
The effects at the low levels are different from the effects
at the higher level. We cannot say, because something was not
more acute at a high level, therefore it did not occur as a radia-
tion related thing.
Mr. Jablon. May I respond to that?
Dr. Morgan. Dr. Martell has asked for the floor.
Dr. Martell. In the context of the last comment, you might
let him go ahead.
Mr. Jablon. I would like to respond in two ways. First, I
would like to refer back to something Dr. Morgan said in his ini-
Dr. Morgan stated that the effects of low-level radiation
were certain things. I am sure he would agree that this is infer-
ential. Nobody, in fact, has ever demonstrated that cancers do
occur at the kind of low levels we are talking about today.
It seems reasonable to believe that we can extrapolate from
effects observed at high levels to what might be found at low
I see that Sister Bertel 1 is shaking her head; no doubt she
will have something to say about that.
In any case, to assume, then, that an effect on the cardio-
vascular system will occur at low levels of radiation when it is
not observed to occur at high levels depends on something other
than human data to substantiate it, and we can all have our own
opinions about what is at work here.
Dr. Morgan. Dr. Bertell?
Dr. Bertell. There are three fuzzy ideas that go around
about radiation, first that all exposure is harmful, secondly,
that genetic damage is observable but it cannot be connected
specifically with certain diseases, and thirdly that there is a
nonspecific generalized effect similar to aging. This is the
kind of vague hypothesis which I tried to address by measuring
what I call the aging effect, because I do not know what else to
call it, but apparently within the human body we have a biofeed-
back system or have certain chemicals which enable us to respond
to change in our environment.
As we grow older, our responses are less perfect, or we are
less able to take care of some kinds of homeostatic adjustments.
From the measurements which I did in the Tri -state study, you can
find a comparable effect from radiation.
In other words, I am talking about something that happens
to you when you are exposed to radiation and which is comparable
to what happens to you when you live over the period of a year
exposed to natural background radiation or whatever else you are
I think what we are dealing with here is not a question of
exposing the whole population and noting that a few people get
cancer. What we are dealing with is the fact that everybody gets
an effect. You have some kind of an insult on the human body
that is measurable, and this happens to everybody, all groups.
Your risk of cancer, leukemia, of perhaps many other things
is increased, and that is where the chance element comes in, but
it is a secondary effect.
Some of this is clear and can be proven. It indicates a
need for further research and research along this line, because
if we do not ask the right questions, no matter now long we study
and look at the data, we are not going to get the answers out of
What I am proposing here is not that all of the questions
are answered, but that there is a new technology available. It
is viable, promising, has already given some results, and needs
to be broadened.
We need to apply this to the data available. We need to ask
Dr. Morgan. Dr. Sternglass?
Dr. Sternglass. There is very serious concern that what we
have just heard about the possibility of a generalized aging ef-
fect that would affect heart disease has in fact happened during
the period of nuclear testing. I would like to show that on one
slide in just a minute. (See Figure 1.)
This is a plot of the disease called arteriosclerotic heart
disease, identified by the International Disease Classification
Number 420, for the period 1945 to about 1970.
It shows the mortality rate per 100,000 for the states of
New Mexico, Utah, Georgia, Texas and Illinois.
As you can see, also from the data for the U.S. average,
there was a very sharp and unexplained rise starting about '48
when this classification of disease was introduced. It sharply
rose and peaked just exactly at the time of the end of nuclear
You can see from the dots marked U.S. 410-13 that it has come
down very rapidly since then. This is now supported by animal
studies that show that animals given high doses of radiation and
cholesterol together develop a high incidence of arteriosclerotic
I suggest it is this kind of synergistic effect between rad-
iation and cholesterol that is totally unexpected which is some-
thing that we must absolutely look into.
The same increase and decline in heart disease we have now
seen in Europe and we have in England and Wales, in proportion to
the amount of strontium 90 deposited from north to south, just as
for New Mexico, Utah, and Georgia where we find there is an in-
creasing amount of rainfall and a proportionate increasing amount
of strontium 90 in the milk.
Until we have fully resolved this kind of a possibility, that
arteriosclerotic heart disease may be produced by a combination of
dietary chemicals and radiation, I think to go ahead with the
major reliance on nuclear energy with associated emissions of nu-
clear plants could be a disaster for our nation.
Dr. Morgan. Dr. Archer?
Dr. Archer. About the figures that Dr. Sternglass was show-
ing us; it occurred to me that this sort of situation can result
when the composition of the population is changing. A lower birth-
rate could well appear on some of the mortality charts. That in-
creases death rate and things.
Dr. Sternglass. I will comment on that.
We examine this by age group as well. Each age group shows
it independently. Furthermore cancer in Japan and heart disease
in the U.S. has come down sharply again in recent years, and the
same kind of pattern occurred in countries with very different
LAST A+H TESTS
Mortality Rote for
.t ♦ ♦
JRf^'CH iLt CHINESE
* Tccr USSR NEVADA LAST US-USSR-UK
TEST A-TESTS ATMOSPHERIC TESTS
I .... I ■ ... I .... I .... 1 ... I . ■ . . I
1940 '45 '50 '55 '60 '65 '70 '75
economic and social economic factors. It is a worldwide pheno-
menon, the sudden rise and sudden declines in arteriosclerotic
heart disease associated with the onset and decline of nuclear
I do not mean by any means to claim that this proves beyond
a shadow of a doubt what I am saying. We are dealing with un-
known amounts of alpha emitters that may be getting into the ar-
teries. We know from animal studies and recent human studies of
women who had been exposed to post-operative radiation treatment
for breast tumors, that a number have developed arterial compli-
This has been published in Radiology (Consequences to Radi-
ologists and Medical Specialists), recently. We know that radia-
tion is indeed able to induce arteriosclerotic heart disease in
Dr. Morgan. Dr. Bertell?
Dr. Bertell. Many of the already published radiation arti-
cles also include cerebrovascular disease. For example, in the
ankylosing spondylitis study, class D, which was not supposed to
be in any way associated with the disease itself, had a signifi-
cantly high rate of occurrence among the people. This disease
class D included the cerebrovascular and other circulatory dis-
The article to which I think Dr. Sternglass just referred
showed consequences of exposure to ionizing radiation for medi-
cal specialists and radiologists. Mortality from cancer, cardio-
vascular-renal disease, and all other causes combined were in-
creased in societies with high exposure to radiation.
This is across the board. It also occurs in Hiroshima and
Nagasaki data but primarily at the low and moderate exposure
levels, not at the high exposure levels.
Dr. Morgan. Mr. Jablon?
Mr. Jablon. For deaths from vascular lesions of the central
nervous system -- strokes, that is to say -- I do not know just
what vms meant by low dose, but at the lowest range we have, which
is zero to nine rads, the mortality in Hiroshima was 74 percent
of the Japanese standard and in Nagasaki 95 percent.
So in both cases, it was lower than the Japanese national
In neither city, is there any radiation group that signifi-
cantly differed from any other group in terms of mortality from
For diseases of the circulatory system in Nagasaki, there
are no significant differences. In the zero to nine rads group
the mortality ratio was 93 percent of the Japanese standard; ten
to forty-nine rads, 113 percent. This is up a little bit, but
the differences were not statistically significant. In Hiroshima
also there are no differences: zero to nine rads, 85 percent; ten
to forty-nine rads, 80 percent; fifty to ninety-nine rads, 100 per-
cent of standard Japanese mortality.
I do not see any evidence in these data of any effect on the
Dr. Morgan. Dr. Bertell?
Dr. Bertell. What I am quoting is a study of mortality of A-
bomb survivors by Beebe, Kato, and Land.z./ There were deaths from
allergic diseases, endocrine system, metabolic and nutritional
diseases. Then there is a good deal of discussion, 53 deaths from
diabetes among Hiroshima males; 49 deaths from the entire sample
They go on to discuss the significance of the linear trend,
then they rule it out as radiation related because it did not oc-
cur at higher doses.
The deaths occurred primarily in the age group from 40 to 59
at the time of bombing. The increased risks of death for diabetes
mellitus, cerebrovascular disease and heart disease were striking.
That was where I took the information from: Radiation Research,
Volume 48, pages 613 to 649.
Mr. Jablon. I would like to say just one word about that.
You know that there is, I think a statistical fallacy based
on the principle, that if you give an event of low probability
enough chances to happen, it is going to happen eventually.
You are talking about a report where some twenty different
causes of death were examined. They were examined separately
for two cities and for two sexes, That multiplies the comparisons
Now we have 80 comparisons and there are 5 age groups, which
makes it 400, and there are several different radiation exposure
groups which can be contrasted within each of the 400; not to find
some significant differences in that mass of data merely by chance
would be incredible. There would be something suspicious if it
did not happen.
Therefore, when one finds an occasional discrepancy, one has
to examine it to see if it makes any sense, whether it is consis-
tent by city, by sex, by dose or something of that sort. Other-
wise, you do not know where you are.
Dr. Bertell. I guess what I think is really remarkable about
a possible occasional discrepancy is that it also agrees with what
we found in the Tri -state data. It agrees with what was in sever-
al other studies.
I think that was a criterion which the Commission used it-
self. They said they had performed thousands of tests and the ul-
timate test would be in agreement with other bodies of data.
Dr. Morgan. Dr. Bross?
Dr. Bross. I believe that the discussion has rather charac-
teristically gone off to the direction it eternally takes. It has
dealt with an abstract issue. But this is a public health issue
and it should be dealt with by this panel as such.
The statement has been made that there is no evidence of hu-
man beings exposed to low-level radiation. I would say that our
data is entirely based on diagnostic x-rays which are at this
level or lower. We are not, and let me emphasize this, we are
not extrapolating from very high levels to very low levels. We
are talking about actual data on human beings exposed. In order
to make this clear, I will say a little about where this data
It is coming from the Tri-state data on a population base of
13 million people in designated parts of three states. Nearly
all the households with cases of leukemia during a three-year
period and a random sample of households in the same area were
The persons interviewed were asked about diagnostic expo-
sures and their exposures were validated against hospital records.
These costly and arduous procedures, including the double-blind
interview, and a first-rate staff, headed by Dr. Abraham
Lilienfeld, assured that these data are just as valid as any data
produced by an animal study.
The study size is 13 million persons, not 13 mice. The re-
source that we have here was, in fact, mentioned in the BEIR
Report and then ignored. This information gives a clear picture
from actual data of the hazards of persons exposed to low-level
radiation. And in fact, if anyone takes the trouble to look at
the published -- I emphasize published -- literature that I now
list, there are now one dozen papers, published in quality sci-
We are not talking about abstract issues. We are talking
about public health issues. We are not talking about hypothe-
tical data; we are talking about real people being killed by radi-
Dr. Morgan. Dr. Bond?
Dr. Bond. Dr. Bross, I shall simply add that what data were
available at the time that the BEIR deliberations were made were
taken into account. You indicated that your material was re-
ferred to in the BEIR Committee Report -- I can easily give you
chapter and verse -- and it was taken into account in the deliber-
ations of that Committee.
I have also some of your data with respect to potential ef-
fects on unborn children. They also were taken into account.
You have published these in the open literature, and they have
been criticized. I have the criticisms that indicate that the
data do not necessarily prove the conclusions that you drew, and
that there are other conclusions possible from the data.
Dr. Morgan. Dr. Bertell?
Dr. Bertell. I would just like to state again, we are not
really dealing with opinion but hard data, and not only the Tri-
state data, which I know I have spent five years with and feel
pretty conversant with, but also if you take a look at the other
published data from the Hiroshima and Nagasaki and also from other
studies, you will find that much was reported at low-level as
unexplainable, and it is in there. It is in the published re-
ports. This effect was disregarded since it did not become worse
at higher doses.
We need to take a new look at that whole body of data which
is being quoted as supporting standards which I think are no
Dr. Morgan. Mr. Jablon.
Mr. Jablon. I just wanted to say in response to some remarks
about hard data that, in fact, there are very few hard data that
are pertinent to radiation effects in man. We do not make experi-
ments on men.
Every one of the studies that has been cited has been an ob-
servational study. You look at it and try to squeeze out of the
data, the best information you can get. You never know whether
the persons who have been radiated are like other persons, or dif-
fer from them in other respects than the radiation.
I would like to say also that, on the issue of pre-natal
radiation, the Tri-state Leukemia Study, a very good study, is
far from the only study in that field. In fact, data from various
studies, including one by Dr. Li 1 ienfel d ,5./ whose name was men-
tioned, are rather contrary.
Just what the picture is there is not entirely clear.
Dr. Morgan. I think we had better go on to the next ques-
tion. Dr. Bross?
Dr. Bross. I believe there is an issue here before the group
as a whole that they should recognize. We are being challenged,
insofar as our epidemiological studies are concerned, by persons
who not working in this line.
In the study in Japan, for example, the control was taken as
under 10 rads, and this is what we are talking about, the under 10
The point I want to make is this. I have half a dozen major
epidemiological findings to my credit, not in this field alone,
but in others. If we are going to put this on the basis of who
knows more about epidemiology, a gentleman that you have heard
from or me, I think we should put our records in evidence.
Dr. Morgan. Dr. Archer?
Dr. Archer. I would like to state here that the answer to
the problem of very low levels of background radiation can only
come through epidemiological studies and studies of extremely
large populations. This approach is feasible because in our
natural state, as we live in the world, the background radia-
tion differs in different places.
These differences in background radiation, from which we
can demonstrate differences in effects, both genetically and by
cancer incidence provide the best approach. I think one of the
problems with this approach in the past has been that we have
not been measuring our background radiation properly, so we have
not been able to contrast proper groups.
May I have my first slide, please?
We have a new approach, I think, which promises to give us
some more real information at background levels of radiation.
This slide is a map of the United States with countours across
it, which are the countours of the measurement of the horizontal
component of the geomagnetic forces of the earth.
The center of the horizontal component is somewhere near the
southern end of the Hudson Bay. These are the contours of in-
creasing horizontal geomagnetic force.
The measurements are in gammas, or gauss. The effect of
this force on background radiation, especially cosmic radiation,
is rather fundamental, because this force extends beyond the at-
mosphere for thousands of miles.
When the electrically charged particles from cosmic radia-
tion arrive, they are diverted and their paths are partially
directed by this horizontal geomagnetic field. By using this
force as our guideline and choosing our populations for compari-
son, I think there is a good chance that we can learn more about
the effects of background radiation.
Slide two, please.
This gives the frequency contours of neonatal deaths from,
congential anomalies based on a report of Dr. Wesley in I960.-'
These contours across the United States show the highest rate in
the north eastern part, and lowest rates towards the southern
part of the nation.
Slide three, please.
This slide shows a similar geographic pattern for leukemia.
It does not correspond exactly with horizontal geomagnetic force
lines, but it has a resemblance.
Slide four, please.
This slide shows distribution of cancer of the stomach.
Again, you can see the same contours of death rates for cancer of
the stomach which corresponds roughly to geomagnetic force lines.
SI ide five, please.
This shows distribution of breast cancer. These contours
are similar to the two preceding slides, especially in the east-
ern part of the U.S. The pattern is less consistent in the west-
ern states, because the West was settled later, and many of those
persons who are dying there grew up in the East where the geomag-
netic levels (and cosmic radiation) are higher.
That is all of the slides.
Essentially what I am trying to point out is that in past
studies what has been measured as background radiation is mainly
gamma radiation. That does not differ very much over the nation.
In fact, the highest level of gamma radiation is in Colorado which
does not have the highest rates for congential anomalies or cancer
I think what we have been overlooking in these background
measurements are the particles. There are a lot of nuclear par-
ticulates in the cosmic radiation which have been discovered since
earlier studies were made, and these particles are the components
of cosmic radiation that are influenced by the geomagnetic fields.
Some of these particles are ten to over 100 times as efficient in
producing chromosome injuries as gamma rays are.
\! Stewart, A., Webb, J. and D. Hewitt. Survey of Childhood
Malignancies. British Medical Journal, v. 1. 1958: 1495-1508.
y Gibson, R.Q., Graham, S., Lilienfeld, A.M., Bross, I. et al .
Leukemia in Children Exposed to Multiple Risk Factors. New
England Journal of Medicine, v. 279. Oct. 1968: 906-909.
y Bross, I. and N. Natarajah. Leukemia from Low-Level Radia-
tion; Identification of Susceptible Children. New England
Journal of Medicine, v. 287. July 1972: 107-110.
4/ Beebe, Kato, and Land. Study of A-bomb survivors. Radiation
Research, 1971: 613-649. (The fourth report in a series.)
5/ Diamond, E.L., Schmerler, H., and A.M. Lilienfeld. The Rela-
tionship of Intra-Uterine Radiation to Subsequent Mortality
and Development of Leukemia in Children. American Journal of
Epidemiology, v. 97. May 1973: 283-313.
y Wesley, J. P. Background Radiation as the Cause of Fatal Con-
genital Malformations. International Journal of Radiation
Biology, v. 2. 1960:97-118.
79-767 O - 76 - 3
Dose-Response Relationships, Linear or Non-Linear?
Dr. Morgan. Let us go on to the next question.
Question 3: Do these effects that we are talking about in-
crease linearly with increasing dose?
I believe data suggests that the cancer risk can in a sim-
ple way be expressed by an equation such as, R, the risks, equal
a constant, C, times the accumulated dose, D to some power, N in
R = CD^
In the case of low LET radiation, for example, X, gamma and
beta radiation, the accumulated dose, D, must be corrected for
repair of damage over time, as pointed out by Dr. Bond in which
it does appear in most cases that N is equal to or greater than
1, suggesting the greater efficiency of multiple hits.
In the case of high LET radiation, however, such as alpha
and fast neutrons, there seems to be little or no repair and best
fit curves are obtained when N is less than 1, indicating the
damage per rem is greater at lower doses.
Dr. Baum (J. Baum, Health Physics Society, Houston, Texas,
1974) and many others have shown that in the case of human ex-
posure to radium the best curve fit for cancer induction is when
N is equal to 1/2. Thus, for high LET radiations, such as those
from Plutonium 239, the linear hypothesis underestimates the risk.
In a recent paper,-/ I gave five additional reasons why the
linear hypothesis as now applied is nonconservative. I might
summarize as follows:
1 - Extrapolations are often made to zero of effects on
animals and man, and they are sometimes extrapolated from the
high dose descending portion of the parabolic curve where there
would be overkill .
2 - Estimates are made from exposures to animals of short
life spans, and for a man (as pointed out in the BEIR Report),
out to only about twenty years. Of course, other data over the
remainder of man's life would have to increase the slopes of
these curves or the risks per rem.
3 - A uniform population is usually assumed taking little
account of the age distribution and the disease patterns, as Dr.
Bross has pointed out.
4 - There is cell sterilization at the higher doses and so
it is somewhat risky to extrapolate from these doses because you
would underestimate the risk at low doses.
5 - I think quite important is the fact that recent data
from Drs. C.W. Mays and H. Spiess on radium 224, a bone surface
like Plutonium and other actinide elements, indicate that the can-
cer risk increases with protraction of the dose. This is just the
opposite of what we have observed from low LET radiation.
In summary, I would state that it is my opinion that the
linear hypothesis is always nonconservati ve for high LET radia-
tions. Usually it is nonconservative for in utero exposure of
children to low or high LET radiations, but in some cases of adult
exposure, it is probably conservative for low LET radiation.
I am sure I have provoked a lot of discussion.
Dr Morgan. Dr. Sternglass.
Dr. Sternglass. I would like to say that at the recent hear-
ings by the EPA on radiation standards for the nuclear fuel cycle
I presented evidence obtained by many people in the literature
that at the very low dose rates that we are talking about, we are
dealing predominantly with a different biological mechanism than
we are dealing with at the high dose rates.
The recent data by Dr. Petkau-?/ show that as the dose rate
decreases, it takes less and less dose to break a cell membrane.
This evidence was not available at the time of the BEIR Report.
What it means is simply this, that for somatic, not gene-
tic situations, we are now faced with a whole new problem, namely
the fact that when cell membranes are injured as a result of
indirect chemical effects the data of Dr. Petkau both for free
membranes and his new data on micro-organisms and mice, show
clearly that the lower the dose rate is, the less it takes to
break a membrane.
As a result, one is led to a non-linear effect at low doses,
which is opposite to what we had expected in the past. In fact,
the curve of response versus dose goes up much more rapidly at
the origin to the degree that this leads to an under-estimate of
biological effects of very low doses using a linear extrapolation
of something like a few hundred, possibly as much as a thousand-
Now recent studies have shown that membranes are involved in
the functioning of the immune system of the body. One of the
most important things about the immune system is that it not only
defends the body against viruses and bacteria, but we now know
from recent evidence published in the last few years, that the
immune system also detects and controls cancer cells.
Thus, we are now faced with the evidence that cell membrane
damage is possibly the controlling one in cancer induction at low
dose rates, while at high dose rates, the controlling process
seems to be direct damage to the DNA.
This means that we now have a mechanism that we did not have
before that can explain not only the very large increases in in-
fant mortality, but also the changes in heart disease and cancer
all over the world following the period of nuclear testing.
These kinds of data were simply not available before Dr.
Petkau's data and the recent studies on animals at low dose rates
I agree with the Chairman, Dr. Morgan, that we have evidence
that protracted radiation at both low and high LET in some circum-
stances may be more effective in producing damage than we expected.
It is precisely to this point that I would like to address
mysel f .
I would like to show, very briefly, with the help of a couple
of slides, the nature of the evidence that indicates that we have
such a problem. (See Figure 2.)
Now, this is the data of Dr. Petkau which shows very clearly
that, as you go down in dose-rate from right to left, the dose
required to break a cell membrane declines. In fact, it takes
3,500 rads to break a membrane with a brief pulse of medical x-
rays. But it takes less than one rad to break it at one millirem
Therefore, as one goes down towards background dose-rates, it
is more easily broken. This has now been shown also in living
organisms by Dr. Petkau contrary to what Dr. Bond has said.
Secondly, I would like to show that a much greater than ex-
pected effect at low doses and dose-rates also has been recently
confirmed in animals studies for polonium, published by J.B. Little
and co-workersl/ . (See Figure 2.) It shows at very low doses
the risk of cancer goes up very sharply near the origin, then
levels off at high doses, exactly as one would expect for a mem-
It shows that only towards higher dosage is the curvature of
the dose response curve concave upward.
If one extrapolates from the high doses, as we have in the
past and as was done in the BEIR Report, and draws a straight
line to the origin, one greatly underestimates the effect that
would occur at very small doses near zero, and this has now been
found in a number of animal studies, including that of Dr.
Sanders at Battel le-Northwest Laboratories and other animal stu-
dies . (See Figure 4. )
The fact that it can also be seen in human populations is
perhaps most strongly illustrated by the changing cancer rates in
Japan between 1920 and 1965 or '70. (See Figure 5.) Here we see
that between 1920 and 1950, during the period of enormous increases
in industrial and chemical pollution and the addition of food
additives, there was no significant rise in cancer, and that the
rise in cancer began within three to four years after Hiroshima
and the huge tests in Siberia that dropped heavy radioactive fall-
out on Japan.
Furthermore, the upper line shows what happened to the U.S.
non-white population that includes, of course, Japanese, Chinese,
Indians and Negro populations in this country. It shows an enor-
mous, sharp rise beginning a few years after the fall-out began
0.001 0.01 0.1
DOSE RATE (rad/min)
Data of A. Petkau, Health Phvsics 22,
239 C'arch, 1972)
POLONIUM- 210 EXPOSURE and
LUNG CANCER IN HAMSTERS
(J. B. LITTLE et al. Science /
Moy 16, 1975 , VoL 188, p.737
DOSE IN RADS
CANCERS PRODUCED BY
PLUTONIUM- 238 IN THE RAT
(C.L. SANDERS, RAD. RES. 56 , 540, 1973 )
100 200 500 400
DOSE IN RADS
AGE-ADJUSTED CANCER MORTALITY
RATE. U.S. and JAPANESE MALES
all ages, all sites, rate per 100,000
( M. Segi et al. ,
Japan Cancer Society)
(NOV. 1972 ) MORATORIUM
(SMALL, LOW ALTITUDE
I— U.S.S.R. A-TESTS
1-^* NEVADA 2— NEVADA
to come down, with doses that were never much greater than 20 to
50 millirems per year, showing a brief decline four to five years
after the test moratorium, and rising again following the second
increase in fall-out from the second test-series.
Furthermore I just received data from Japan, from Dr, M.
Segi in Japan, that shows that beginning in about 1970-71, cancer
rates have begun to turn around in Japan, halting their rise sud-
denly and actually beginning to drop for prostate cancer, leuke-
mia and other cancers of relatively short latency period.
In fact, I will show you the case of how dramatically one
cancer in particular rose, which medicine has been unable to treat
successfully, namely cancer of the pancreas. (See Figure 6.) It
shows that it was completely level and horizontal during the time
of the worst chemical pollution between 1930 and 1945 and then
shot up 1200 percent in a matter of a few years.
Anyone who can say that this does not suggest the possi-
bility that we seriously underestimated the effect of very small
levels of radiation does so at the risk of disregarding public
I would like to point out what I think is sometimes not
clearly understood. I fully agree with you that at this moment
diagnostic x-rays are the source of the greatest x-ray exposure
to our population. However it now appears in the light of the
new evidence of greater effects at the very low dose rates, that
at the rates of environmental radiation, we are experiencing a
phenomenon for which we were not prepared by our studies of medi-
cal x-rays. It is suggested that because medical x-rays are given
at a very high dose rate, they may have a much smaller somatic
effect for a given dose. I would just like to illustrate this
with one slide here that I believe makes it clear how this error
came about, since we did not have any of this experimental infor-
mation until about three or four years ago. (See Figure 7.)
What I have here is a plot of the so-called critical doubling
dose in rads going from 1/1 000th of a rad up to 100,000 rads as a
function of dose rate, where the dose rate is given in rads per
minute. In the middle we have about one rad per minute. For the
bomb radiation, we have about a thousand to ten thousand rads per
minute. For fall-out, we have about 1/10, 000, 000th of a rad per
All of our previous standard-setting and all of our medical
experience is based on the assumption that the genetic damage is
dominant and that the dose needed to double the normal incidence
is about 10 to 100 rads, and that this applied to cancer also.
Most importantly, it was assumed that this was essentially inde-
pendent of the dose rate.
However, our medical experience only extended roughly from
10"-^ rads per minute up to the A-bomb radiation rate of a few
thousand rads per minute, but the portion of the curve between
10-3 and lO''' rads per minute had remained essentially unexplored
either in human or animal studies. It was only in the last few
years that Dr. Scott and other researchers began to investigate
I0~° . 10
FLUOROSCOPY y-L, A-BOMB
what happens at the extremely low dose rates for which we had no
What I am now suggesting on the basis of this new data is
that the cell membrane damage seems to be coming into dominance
at these low dose rates and that this could explain why we were
misled by our relatively fortunate experience with medical x-rays.
In fact, when I wrote my book in 1971, I was absolutely convinced
that linearity was the best possible choice to make for estimating
the likely effect of background radiation. But in view of these
new discoveries of membrane damage and its relation to the immune
process, I seriously question whether medical radiation is indeed
the greatest source of our biological damage, although it is cer-
tainly true that it is the greatest source of our exposure. But
it is given at a very high dose rate and this, I believe, is cru-
cial and needs much further investigation.
Certainly the fact that in Japan for 30 years between 1920
and 1950 the cancer rates did not rise throughout the period of
growing use of medical x-rays as Dr. Segi's data shows, I believe
indicates that medical diagnostic x-rays, although they are large
in dose, fortunately are not the biggest source of our cancer
Dr. Morgan. Dr. Richmond?
Dr. Richmond. I think I would like to respond to the comment
that was made by the previous speaker. Dr. Sternglass.
The public has been exposed very often to claims that there
are increases in infant mortality, of various diseases, cancer,
etc., as a result of releases of materials from nuclear facilites.
I think that the record clearly states that in every case
where this allegation has been made, investigations followed by
responsible state or Federal agencies did not support the alle-
gations. They were all found to be false.
Dr. Sternglass. That is not the case. As a matter of fact.
Dr. Morgan was present at one of these hearings. All that could
be said was that it was not possible to decide with the particular
data in a single situation whether or not the observed rises and
declines in cancer rates and infant mortality were, in fact,
definitely associated with radioactive releases.
Dr. Morgan. Dr. Bond?
Dr. Bond. I would like to state, in response to Dr. Stern-
glass, that the data to which he referred, by Dr. Petkau were ob-
tained on non-living materials. It is difficult enough to extra-
polate from lower living materials to man, let alone from non-liv-
ing material .
With respect to his responses to Dr. Richmond. I would like
to say I have in front of me a single document. 1/ It is a sum-
mary of responses to ten years of allegations that Dr. Sternglass
has made. The overall conclusions from detailed analyses of the
same data that he has used with respect to infant mortality are
that, without exception, the conclusions Dr. Sternglass has drawn
with respect to infant mortality were not supported by the data
presented by Dr. Sternglass.
Dr. Morgan. Dr, Mattson?
Dr. Mattson. Mr. Chairman, I think we should try to get back
to the agenda, and the issue at hand today. People have said sev-
eral times around the panel that the issue is a public health is-
sue. The primary concern of this public health issue is the set-
ting of radiation standards to protect people.
What we have heard in this opening dialogue is the nitty-
gritty of the scientific research. It is important research, but
the dialogue does not help us get directly to the question of
whether the standards are any good.
I thought that I ought to say something on this, because this
is my job as a regulator, as a protector of public health and
safety and one who works with standards. These are the kinds of
decisions we make day in and day out. Given the tens of thousands
of reports by people like those reviewed by the BEIR Committee and
by some of you here today, how do we come to a consensus of scien-
tific opinion of how to protect people from low levels of radia-
I think Dr. Morgan said it well at the start of this question.
There is no hard, direct evidence of a link between health effects
and low-level radiation. Despite that, radiation standards today
are set assuming that there is a direct relationship.
That is what the linear hypothesis is all about. We use a
linear dose/effects dependence, that is, the same number of ef-
fects per unit of dose that is observed for high level radiation.
We continue to study that dependence. There are millions of dol-
lars of research going on in the kinetics of cancer, carcinogene-
sis. And dialogue continues day by day. Even with this ongoing
research, we prudently assume such a linear relationship in the
standards that are set today.
Dr. Morgan. I would like to take prerogative as the Chairman
to respond to the exchange of information or statements between Dr.
Sternglass and Dr. Richmond.
Dr. Sternglass was correct in his response with reference to
the Shippingport reactor. I happen to have been a member of the
Governor of Pennsylvania's Committee to look into the allegations
of Dr. Sternglass' referencing the increased incidence of ailments
in the population as a consequence of this operation.
My interpretation as one member of this committee was that
there were no data, no evidence, of statistical significance that
the operation of this reactor had resulted in these effects claimed
in the allegations of Dr. Sternglass. But, on the other hand, the
data were so poor and the information collected from environmental
monitoring as far as health physics was concerned were of such poor
quality, and there were so many corrections to these data and the
biological effects, it was impossible to rule out the fact that there
may have been a relationship between environmental radiation exposure
from the Shippingport operation and an increased death rate in the
Dr. Morgan. Dr. Bond?
Dr. Bond. In 1972, two very extensive studies were made by
two groups, the United Nations Scientific Committee on the Effect
of Atomic Radiations5./and the BEIR Committee of the National Acad-
emy of Sciences. It was made well-known that these studies were
going to be done, and information was solicited from all scien-
tists -- from anyone who wished to submit information.
These two groups studied the same bodies of evidence. In
some ways they came to the same conclusion; in some ways, to dif-
ferent conclusions. They studied both the genetic and somatic ef-
fects, and they took into account the various effects that have
been mentioned so far in the conversation today.
In the UN Report it was recognized what has been know for de-
cades, that radiation does produce long-term effects, such as can-
cer. It was shown that quantitatively one can draw deductions
with respect to effects in the high dose and dose rate ranges. It
was stated that the data were insufficient to allow one to extra-
polate or, more accurately, interpolate with any degree of accur-
acy to effects at low doses and those rates.
Both reports came basically to the same conclusion with re-
spect to the effects of high doses and dose rates. I will not
give the derived risk coeff iciencies , since they are well-known.
The BEIR Committee did use so-called linear extrapolation to
obtain what is considered to be an upper estimate of what might
happen at low doses and dose rates. I am speaking entirely of low
LET radiation; not high LET radiation.
They did use so-called linearity, a straight line, between
effects obtained in high doses and dose rates and background ef-
fect, at zero dose.
In this group it was discussed extensively that recovery oc-
curs in all known biological systems. It was actively discussed
in the BEIR Committee Report Group, whether or not a dose rate
factor should be incorporated into the risk estimates. It was de-
cided that they should not, because, on the basis of purely human
data, one could not make a definitive statement whether dose rate
effects obtained, or did not obtain, and, in the Committee's esti-
mation, animal data were not sufficiently developed.
Since that time, a large amount of animal data has become
available, and the current discussions in the scientific community
generally are that, on the basis of animal data and not contradicted
by other data, one should in fact, introduce a dose rate factor.
This would reduce the effects predicted in the BEIR Report.
The BEIR Committee Report has been discussed extensively, and
its findings in general have held up. It is one of the best com-
pendia of radiation effects data, in my estimation.
Dr. Morgan. Dr. Martell?
Dr Martell. My comments are directed to some of the re-
marks that Dr. Bond made regarding the inadequacy of the BEIR
Report. To keep the record straight, I must point out that when
the BEIR Report was prepared, no adequate consideration was given
to the role of internal emitters, particularly internal alpha
The "hot particle" hypothesis had not been discussed. This
hypothesis involves some rather serious implications about cancer
risks from plutonium which are only now being considered. This
was not touched upon in the BEIR Report. I have raised some ad-
ditional questions with respect to the cancer risks for insoluble
alpha emitting particles of moderate activity in human soft tis-
sue. This issue has also never been discussed.
The whole question of cancer risks which are associated with
internal alpha emitters has been averaged away by averaging organ
burdens and alpha doses without considering the micro-distribution
of alpha emitters in soft tissue and the possible consequences.
In this connection, the real issue is whether or not a multiple
mutation process may be applicable to internal alpha emitters in
the chronic exposure case. If it is, we have seriously underesti-
mated the health effects of internal alpha emitters.
This omission extends to genetic effects as well, particular-
ly because in the BEIR Report it was assumed that internal emitters
contribute only 18 percent, uniformly, to the gentically signifi-
cant background radiation dose. Anyone who has looked at the in-
ternal radioactivity distribution in human organs finds that there
are wide variations for natural and artificial radioactivity. We
now find, in publications over the last several years, that pluto-
nium is present in the gonads at concentrations relatively high
for soft tissue organs with a distribution that will give rise to
even higher radiation doses to the sperm. And it has been known
for some time that for polonium-210, in smokers, there is a much
higher concentration in the sperm than elsewhere in the gonads.
I suggest that internal emitters and their micro-distribution in
gonads, and alpha emitters in particular in the sperm and the ova,
are a serious and almost completely neglected subject. If you
read Chapter VI of the BEIR Report, you get the impression that
only a few percent or less of human genetic effects are due to
radiation and that the rest are somehow due to nonradioactive mu-
tagens. However, it is likely that alpha emitters and other in-
ternal radioisotopes play a very important role in accounting
for the remainder of the genetic effects in man.
Dr. Morgan. Dr. Richmond?
Dr. Richmond. I would like to respond to some of the com-
ments that were just brought up by my colleague. Dr. Martell.
Two items, specifically, one in reference to our alleged lack
of knowledge or state of ignorance about non-uniform distribution
of plutonium and actinide elements in man. I think that this can
best be summarized by what is currently known as the hot particle
hypothesis that was submitted to several government agencies about 2
years ago in the form of a petition to lower the standards for occu-
pational exposure, actually by a factor of 10^, about a hundred-
I will just read to you there is quite a bit of literature
available on this -- some of the organizations that have studied
this question and have not been able to support the hypothesis.
This means that they have not found it scientifically valid
to support the hypothesis that there is a serious defect in the stan-
dards. Alternatively, they have condoned the current means of cal-
culating radiation standards. These include the National Radiolo-
gical Protection Board of the United Kingdom, and the Biophysical
Society of the United States.
These reports were all published or are available to the public.
The National Radiological Protection Board in the U.K. I mentioned.
There are numerous documents that have been written and assigned to
the literature. I will not go into all of these, as there are a
great number. There have also been Federal hearings by the Environ-
mental Protection Agency held in 1974 that considered this issue.
The Medical Research Council of the United Kingdom has reviewed
the issue. The National Council on Radiation Protection in this
country has reviewed the issue. The Nuclear Regulatory Commission
has reviewed the issue. The National Academy of Sciences is current-
ly reviewing the issue.
I think a very good summary is published in the Federal Regis-
ter, Volume 41, Number 71, April 12, 1976. (See Appendix.) This
was a rejection of a hypothesis by the Nuclear Regulatory Commission.
The other issue brought up related to our lack of information,
allegedly again, on plutonium and actinides in gonad tissue. I again
refer to the time-honored mechanism of scientists that we publish in
the literature. Here is a recent article on the concentration of
Plutonium and actinide elements in the gonadal tissues of man. This
is published in the Health Physics Journal. Our esteemed Chairman
has been associated with the journal for many years.
In summary, this shows that there was not a selected concentra-
tion of plutonium in gonadal tissue, including samples obtained from
people. We do understand the effects of radiation, including high
LET, highly ionizing radiation, on gonadal tissues.
Dr. Morgan. Thank you. Dr. Caldicott?
Dr. Caldicott. I am not so sure how we are going to set stan-
dards, or how the present standards will represent what will happen
in the future when we proceed with nuclear fission and the breeder
reactor and produce massive quantities of fission products. We know
we lack a lot of the stuff already. We know two years ago in Hanford,
Washington there was a leakage of 115,000 gallons of highly radioac-
tive waste products into the soil.
We know where it is, but we cannot stop it. It is approaching a
river I cannot remember the name of the river -- the Columbia river.
We know that these fission products are concentrated in the
food cycle; radioactive elements are all concentrated in the food
cycle, in milk in particular. We know that babies drink milk.
We know that 3 microcuries of plutonium deposited in the lung,
which is a small amount, over a period of one year will produce a
radiation of the total lung of 2,000 rems.
I do not think that is a low radiation, but it is a small
amount of plutonium.
This recent paper suggests that plutonium is concentrated in
the gonads compared to the lung and absorbed from the lung, not the
gut, by a factor of 2. It is concentrated in the gonads by a fac-
tor of 2.
I really do not quite understand by the standards we have now
how we are going to control and monitor this when we indulge in
breeder reactors for future generations.
Dr. Morgan. Any further comments on this question?
Dr. Richmond. You have raised many points. I will only stick
to the last one.
You mentioned that there is evidence that there is a concen-
tration of plutonium in the gonads relative to the lung. I happened
to write that paper, and that is not the conclusion. It is one that
you can draw from it, but the point, the conclusion, was made that
there was no selective concentration of plutonium in the gonadal tis-
It is quite interesting that the data show that there is no con-
centrating mechanism in the soft tissues. There can be a concentra-
tion in the lymphatic tissues because of the pathway by which the
plutonium gets from the lung to the regional lymph nodes. But there
is no appreciable concentration in soft tissue.
If you look at statistics of the situation, for example, some
people have looked at that particular set of data and made, I think,
wrong conclusions -- if you stop to think about it, all the material,
if inhaled, is in the lung at some time and at some later time it is
somewhere else. So the level in the lung decreases while it is in-
creasing in other tissue.
I would argue that point very seriously. That is all.
Dr. Morgan. Dr. Martell?
Dr. Martell. Thank you.
I would like to add a comment with respect to the critique of
the linear hypothesis that Dr. Karl Morgan made.
I think he has made an excellent statement to indicate why high
LET radiation, for several reasons, may involve higher effects at
79-767 O - 76 - 4
very low levels and why it is not conservative to extrapolate to very
low doses of radiation.
In this connection, a study that I have been carrying out, in
cooperation with two other research groups,^/ shows that insoluble
alpha emitters are present in cigarette smokers' lungs.
And the small amount of alpha activity involved can only contri-
bute to cancer induction in smokers if a multiple mutation process
is involved. However, if a multiple mutation process is^ involved,
the linear hypothesis would be seriously in error and we could have
very much higher risks for longer exposures to very small burdens of
insoluble alpha emitting particles.
This arises from the fact that, for a multiple mutation process,
one has a self-proliferation of the singly mutated cells taking place
continuously, so that the risk of getting a second particular change
in the same cell is proportional to that number of singly mutated cells
only some of which have been directly induced by radiation, but each
of which will have proliferated according to the mitotic activity of
the cells being irradiated.
As we all know, the mitotic activity is higher for cells in some
organs, and higher in the young. Therefore, the cancer risk will
increase very significantly for the chronic exposure case, and the
earlier such exposure begins, the earlier the effect and the higher
Dr. Morgan. Dr. Bertell?
Dr. Bertell. I would just like to add here that sometimes the
phrasing of the question is misleading and I would submit that the
question: "does radiation have a linear dose effect," is too sim-
plistic for the type of thing with which we are dealing.
In the first place, there are multiple effects, and in the
second place, I think we are dealing with different biological mech-
Unless we refine the question and say: "is this particular
mechanism linear," or: "is this particular result appearing in a
linear fashion," we are obscuring the public health question.
Dr. Morgan. Thank you.
Dr. Archer. Yes.
May I have my sixth slide, please?
I have been engaged in studying uranium miners for more than
twenty years now -- not quite that long, but when we first set Feder-
al standards for them in 1957, I drew an exposure response curve for
lung cancer with all the data we had at the time. Exposures were un-
certain, and the populations were not well defined. We made estimates
of exposures and populations, and drew some curves which I extrapo-
lated to zero dose and zero response. I suggested this be used for
setting the standard.
It was rejected because first the points were somewhat uncer-
tain. Secondly, there was very little information down at the lower
end of the curve. In the years since then we have gathered quite a
bit of information which strengthens the lower end of the curve.
Slide seven on the screen represents some relatively new data
on people who have been exposed to radiation of alpha particles from
radon daughters in ground mines. The points with the "X" on them are
from American studies of underground uranium miners. Of the other
two sets of points, one is from Czechoslovakian uranium miners, and
the other set of points is from Swedish iron and lead mines.
There were fairly good exposure measurements for all three. This
is in the low exposure range, from zero to about 600 Working Level
Months (equal to 1000-1500 rads). You can see that the line goes up-
ward to the right into the thousands of Working Level Months.
The incidence, that is the cancer death rate for lung cancer, is
given on the left axis. The up and down marks give the standard er-
ror for each one of the points. I have drawn one line through the
points by eye. There appears to be an upward bulge near the bottom
end of the curve.
The exposure-response line is straight (linear) except that it
appears to have an upward bulge before it comes down to zero, al-
though the points are sufficiently uncertain that we cannot be com-
pletely sure of that.
Slide eight please.
We took these sets of data and analyzed them with a linear re-
gression analysis. This slide gives the curve resulting from that
One of the other things I should point out, I subtracted the
expected or background lung cancers from all the points. The numbers
of these "expected" cancers are not precise, but reasonably good.
What we are dealing with in these slides are those cancers attributed
to the exposure. The two outside lines in this slide are the 95 per-
cent confidence limits. The lower 95 percent confidence limit barely
reaches the zero point.
Since we are making the curve linear, that little bulge near the
bottom pushes the lower end of the curve up, so it looks as if the
point at which the regression line intersects the ordinate is con-
siderably above the zero point, which I am sure it cannot really do.
The bulge at the lower end of the curve may or may not be real. If
it is real, it means that at very low dose rates, alpha particles
are more efficient in producing chromosome damage than they are at
higher dose rates.
Dr. Morgan. Dr. Bross?
Dr. Bross. In order to be clear on a point, which is an excel-
lent one, which Dr. Bertell made: The effects I want to talk about
are the accumulated genetic degradation and the relationship, the
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question of linearity, with respect to cumulative genetic damage.
We know that radiation produces minute damage points in the
delicate biochemical structure, DNA, of the genetic material of hu-
man cells. We know this very well from human data, that is, from
clinical studies at the kilorad level where the radiation produces
multiple damage points. This particular damage is immediately vis-
ible because a cell cannot reproduce effectively. As were mentioned,
multiple hits are required to block the actual reproduction. Where
you get only a few hits, which must be the case for the cells to
either show up as cancer in human beings who are exposed to radia-
tion, or in the children of that person, then you have to have, in
both cases, a genetic change.
Then you have a different situation.
Incidentally, the reason that kilorad doses are used to treat
cancer are not that they fry cells alive, but that they produce
heavy genetic damage. The damage points are roughly proportional to
However, in low level radiation, you get all the damage showing
up, if you are lucky or unlucky, in the subsequent generations. Where-
as if you get into heavier damage, heavier concentration of damage,
you simply block reproduction and you do not have this effect showing
Dr. Morgan. Dr. Sternglass?
Dr. Sternglass. Briefly I would like to show why this is exact-
ly why the leukemia rate in Japan appears to have gone up so very much.
I would like to show these slides to indicate what damage in the early
fetal stage, which we all agree is the most sensitive, can do if it
happens during the critical time of cell division. (See Figure 8.)
This is taken from Dr. Segi's data on the rise of the incidence
of cancer mortality, both leukemia or cancer mortality of all types
in Japan for the 1940 to 1965 period, and this is per hundred thousand
children, age 5 to 9 years.
You can see that before the bomb, 1935 to '40, there was essen-
tially no rise, in fact possibly a slight decline, in the incidence
of leukemia and childhood cancer mortality. This age group of five
to nine-year-olds for which Dr. Segi gives the data is the one that
Dr. Stewart found to be most responsive to x-rays during pregnancy
in her extensive epidemiological studies in England.
You can see that suddenly, within a matter of a few years, ex-
actly as we have seen in the case of diagnostic x-rays during preg-
nancy, or within about five years there is an enormous rise in can-
cer, essentially a 200 percent increase in the first two and a half
years beginning in 1950. When the number of low-altitude A-bomb
tests leveled off and the high-altitude H-bomb tests began, the can-
cer rates leveled off. Then, following typically on the order of
five to six years after the second test series, there was another
peak, and the latest data show that the cancer rate has begun to come
down again, which is exactly what you would expect.
CANCER MORTALITY RATE
for 5-9 Yr. old moles
in oil of Japan
( From M. Segi el al., Japan Cancer Society)
|il f DELAY
(41 CASES PER YR. Av. )
1940 '50 *60
This, therefore, is one way to show why we have so underesti-
mated the effects of fall-out, because the exposure happens during
the earliest times, during the time when the fetus is most sensitive.
But not only does cancer increase, but there have been changes
also in the ability to fight infections, which radiation is known to
be able to affect. (See Figure 9.)
I am showing here a plot of pneumonia and influenza mortality
in the U.S., again for infants who received radiation in the fetal
We can see here for the entire period 1940 to 1975 first the
sharp drop up until 1945 to 1950 and then a levelling off of mor-
tality rates, actually rising again during the time of greatest fall-
out in 1956-57.
Finally, a renewed drop in mortality rates took place after the
end of testing that has now begun to approach what one would have ex-
pected if there had not been a period during which the fetus was ex-
posed to enormous amounts of internal isotopes.
We are dealing here with a total number on the order of 9,000
to 10,000 infants per year during the 50's. This is clearly not a
small statistical change. The rate is now dropping down again, so
it had not reached its lowest possible level during the 50's.
One could not say that our penicillin and our drugs had done
all they could. In fact, during the last few years, the pneumonia
and influenza rate has resumed its rapid decline.
This suggests that the most serious effect of low-level radia-
tion in terms of total numbers is not the induction of cancer, but
really the effects on the immune system of the human body.
pneumonia and influenza
1/1 MORTALITY ( - I yr. )
1940 '50 '60 '70 '80
]_/ Morgan, Karl Z. Suggested reduction of permissible exposure to
Plutonium and other transuranium elements. American Industrial
Hygiene Association Journal, v. 36, August 1975: 567-575.
y Petkau, A. Effect of ^^f^a"*" Qp g Phospholipid Membrane. Health
Physics, V. 22, March 1972: 239-244.
y Little, J.B., et al . Lung Cancer Induced in Hamsters by Low
Doses of Alpha Radiation From PI utonium-21 0. Science, v. 188,
May 16, 1975: 737-738.
4/ Yulish, Charles B, et. al . Low Level Radiation: A Summary of
Responses to Ten Years of Allegations by Ernest Sternglass in
Proceedings of the Fifth International Conference on Science and
Society. Herceg-Novi , Yugoslavia. Charles Yulish Assoc. New
York. July 9, 1973.
y United Nations Scientific Committee on the Effect of Atomic Rad-
iation. Report to the General Assembly: Ionizing Radiation:
Levels and Effects. Vols. I and II. New York. United Nations
Publications. 1972. (E 72-IX-17).
6/ Radford, E.P. and E.A. Martell, "Polonium-210: lead-210 ratios
as an index of residence times of insoluble particles times from
cigarette smoke in bronchial epithelium", Proceedings of the
Fourth International Symposium on Inhaled Particles and Vapours ,
Edinburgh, 22-26 September 1975, Pergamon Press, Ltd., and
Martell, E.A., "Tobacco radioactivity and cancer in smokers",
American Scientist , 63, 404-412, July-August 1975.
Protection of Special Group s
Dr. Morgan. Going on to question four. What are the various
subgroups besides the general population whose exposure to radia-
tion deserves a special attention, such as uranium miners, workers
at operating reactors, reprocessing plants, etc.?
Dr. Caldicott. I would like to point out as a pediatrician
that there are sections of the community who are far more sensi-
tive to the radiation than others and to these individuals you
cannot apply the linear hypothesis necessary. Infants are 11
times more susceptible to radiation than adults. Older children
are four times more sensitive to radiation.
Children who have asthma between the ages of one to four
have 3.7 times the risk of developing leukemia from radiation.
Children who have allergic disease and who have had inter-uter-
ine x-ray exposure have 24.6 times the chance of developing leu-
The reason that children and fetuses are so susceptible to
radiation is because the cell? are rapidly dividing, and it is
these rapidly dividing cells that are sensitive to radiation.
Extrapolating from this, the fetus in the first three months is
the most sensitive organism in the human life cycle to radiation
because all of the organs of the human being are being formed in
the first three months of gestation.
There are several effects that can occur from radiation
during this period. There can be damage to the developing or-
gans. There can be congenital heart disease or various congen-
This is caused by somatic mutation or mutation in the de-
veloping cell that is formed in that particular organ.
The fetus can be damaged by a mutation within its gonads,
the testes or the ovary, which therefore transmits this mutation
to future generations. There can be damage from another point of
view, from a carcinogenic point of view, in that one of its cells
may be damaged and the regulator gene that controls the rate at
which that cell divides is damaged and the cell may divide.
Hence, the fetus is extremely sensitive to radiation.
Dr. Morgan. Dr. Bond?
Dr. Bond. I certainly agree with what has been said. This
has been recognized for a number of years. It is taken into ac-
count very extensively in the BEIR Committee Report and by other
groups that have to do with setting of standards. Physicians and
others are admonished to keep radiation exposure to the fetus to a
minimum, and actually the exposure standards for the fetus con-
tained in the mother who is a radiation worker are more restric-
tive than for the adults.
Dr. Ellett. Is that true? I thought that this was not true.
Dr. Bond. It is a recommendation -- it is a firm recommenda-
tion of the NCRP.
Dr. Ellett. The NRC did not change the recommendation.
Dr. Morgan. Please speak into the microphone.
Dr. Bond. Let me say that the recommended standards apply to
the fetus, which of course, of necessity, applies to the mother.
Dr. Morgan. Dr. Ellett, did you wish to comment?
Dr. Ellett. Yes.
We will get into this later, but it might help to clear
things up a little bit now.
When we say standards, we have to be careful about what we
mean. Dr. Bond referred to recommendations from the NCRP. These
are recommendations, not standards. They have not been implemen-
ted by standard-setting agencies, that is as far as I know.
Let us be careful today, because we are dealing essentially
with a lay audience. In referring to a recommendation by NCRP --
let us say "recommendation." When we say "standard," let us re-
fer to something that is law, i.e. legally binding.
This is, in a sense, a governmental hearing to see how infor-
mation can be used by the Congress. I would not like them to have
a false impression that things exist that do not exist.
Dr. Morgan. Dr. Mattson?
Dr. Mattson. Dr. Morgan, one brief comment.
Dr. Ellett properly said that the ICRP and the NCRP have made
recommendations regarding the dose to the fetus being limited to
some lower number than the occupational exposure limits for adults,
since the increased radio-sensitivity of children which we are dis-
cussing here today has been pretty well accepted by radio-biolo-
gists for some years now.
Present Federal radiation standards do not now contain such
a provision. Such a provision was recommended by the Atomic Ener-
gy Commission in January, 1975. It was put out for public comment
at that time.
In following through on that recommendation, the people I
work for have issued a guide to females employed in the nuclear
industry, the people that we license, telling them of this in-
creased radio-sensitivity of the fetus should they become pregnant
and advising them of the actions that are available to them under
You can well imagine that there are other competing interests
in this nation with respect to discrimination in employment of
women, if there were different radiation standards, and with re-
spect to invasion of privacy. There are several points of law
that act very strongly in this field, one being the Supreme Court
decision on abortion; the other being Title VII of the Civil Rights
Act of 1964.
Dr. Morgan. Thank you. Dr. Mattson. Dr. Archer?
Dr. Archer. I think we can summarize these special subgroups
exposed to radiation fairly quickly.
If we skip the entire population, who are exposed to back-
ground radiation, ignore the exposure of everybody to radiation
from nuclear reactors and a little bit of nuclear fall-out, we can
summarize occupational exposures quickly.
There are a number of occupational groups who are exposed to
radiation, and in the past, there have been considerable numbers
of over-exposures. These were mostly among medical radiologists,
x-ray technicians, dentists, and dental technicians. There have
been a number of studies showing excess cancer among these groups.
But, with the advent of modern radiation protection tech-
niques and controls, it is my feeling that few of them are being
really overexposed any more. Uranium miners are another group
that has been overexposed in the past; we now have an exposure
standard for them which gives them substantial protection. I am
not at all sure that the mine operators can reduce exposure much
more than they have done.
There is still some risk for uranium miners, I think, just
as there is some risk in all radiation exposure.
Luminescent dial painters are another exposed group. They
formerly used radium for painting dials on watches, clocks, etc,
and developed many bone cancers as a result. Introduction of good
handling techniques and a switch to tritium has eliminated this
In the practice of medicine in the past, some patients have
been overexposed to radiation. The most noted ones are those who
were injected with solutions of radium or thorium for various rea-
sons. Thorotrast (containing thorium) was used as a medium for
x-ray contrast. Those radioactive substances are not being used
anymore. However, there are some physicians, especially dermatol-
ogists, who use x-rays to treat some nonmalignant diseases. Such
treatment sometimes results in worse disease than the patient ori-
It seems to me that this overexposure is unnecessary. In
the past, some patients, like tuberculosis patients with gastro-
intestinal symptoms, have received overexposure to x-rays. There
is little overexposure now of tuberculosis patients. For some
types of gastrointestinal symptoms, it is still standard to order
a gastrointestinal series of x-rays periodically. That has be-
come unnecessary now in many cases because there are better tech-
niques for investigating disorders of the esophagus, stomach, duo-
denum and colon. I am referring to the flexible fiberoptic endo-
scopes. Workers in plants reprocessing uranium fuel are about the
only persons in the nuclear industry who are likely to be current-
Dr. Morgan. For the record. Dr. Archer, I wonder if you
would indicate to us how many cases of carcinoma among uranium mi-
ners have occurred?
Dr. Archer. I can tell you about our study group of uranium
miners. 1/ We do not know how many uranium miners there are. We
have estimated that there have been somewhere between 15,000 and
20,000. We have about 4,000 of them in our study group.
In the study group, there have now been 170 lung cancers.
Over half of those are of the small -cell undifferentiated type.
This type is much more frequent among uranium miners than other
Mr. Goodman. I would like to ask if any studies are being
made of the populations in the vicinity of the mill tailings?
Dr. Burr. Offhand, I do not know of any.
Mr. Goodman. May I recommend such?
Dr. Burr. You may. We have had studies in some of the high
background areas in South America. We have not been able to do
studies in comparable areas in India. India has been doing studies
Mr. Goodman. If we may return to the United States --
Dr. Burr. We are continuing studies of uranium miners. I
did not mention this.
This work now is devoted more towards studies of sputum cy-
Mr. Goodman. Some fifteen years ago, Schubert and Lapp re-
ported in their book some 5,000 low-level plutonium exposures at
Is anything being done, epidemiological ly, about those work-
Dr. Burr. The Transuranium Registry involves the plutonium
workers. This is the study that has been going on a number of
years and is a follow-up study, and does involve the Hanford work-
I mentioned that more recently we have initiated, at the Los
Alamos Laboratory, an epidemiological study of the plutonium work-
ers that will be more extensive.
The answer to your question is yes.
Dr. Morgan. Are there any further questions?
Thank you very much.
Was there anybody else from ERDA?
Dr. Burr. May I say a word? We have not had studies of pop-
ulations in the vicinity of mill tailings. We have certainly had
a lot of work assessing the various mill tailing sites and there
has been a study at Grand Junction --
Mr. Goodman. I made recommendations about that in '65 that
were totally ignored.
Dr. Ellett. The Registry has come up several times today. I
understand the participation in this is voluntary. I have no idea
what kind of voluntary compliance you have with this. Is it 10
percent of the workers involved, or 1 percent?
The figures I saw were quite low.
Dr. Burr. I would like to pass that question on to Dr. Marks.
Would you come to the microphone and comment on this matter, Dr.
I introduced him before as a pathologist. He is also the co-
ordinator for our Human Studies.
Dr. Marks. The level of participation varies greatly from
one facility to another. The representation is very high in the
Hanford plant and lower at other plants.
Dr. Ellett. Could you give us the number, sir?
Dr. Marks. At Hanford, of 2367 employees identified as trans-
uranium workers, the Registry obtained releases for access to the
employees' health physics and medical records on 2174.
They have obtained agreements from 525 of that number in ad-
vance of their deaths to have autopsies performed on them at death.
The problem with autopsy permissions is that this is a very sensi-
tive subject and necessarily voluntary. Many people have a pre-
judice against making arrangements in advance to have autopsies
performed after their deaths.
At Los Alamos, health physics and medical record releases
have been obtained for 259 workers, and autopsy permits obtained
on about half of those.
At Rocky Flats, 1772 transuranium workers are identified.
There are record releases on 1611 of those and advance autopsy
agreements on 173.
Dr. Ellett. Could you give us Savannah River?
Dr. Marks. Savannah River formerly were not participating
in the program. The Savannah River plant is now an active parti-
cipant in the Registry, but we do not have figures on the current
status of enrollment of the plant employees in the Registry.
Does that answer your question?
Dr. Morgan. Thank you. Dr. Bross, I believe perhaps you
could direct most of your response to the special groups where
there are concurrent insults and the effects that may suggest
some synergism between these relationships?
Dr. Bross. I think that all of us are exposed to x-rays
or other radiation from various sources. I think the problem
is cumulative genetic degradation rather than a single exposure
-- as that you have mentioned.
The problem is really more difficult than is recognized be-
cause in addition to people who are obviously exposed there are
other groups in the population that have unusually high risk.
For example, patients who go to a physician who practices defen-
sive medicine and uses x-rays against malpractice. Or young wo-
men under 50 who have enrolled in a radiological surveillance
program which is intended to reduce the deaths from breast can-
cer, but (in this group under 50) may have just the opposite ef-
Then there are patients who go from one doctor to another
with obscure maladies and get a whole new series every time, be-
cause there is very little provision for transfer of information,
and so on. These are groups which are difficult to protect un-
less you deal with the whole problem of controlling the sources
of radiation that are being given to the population. To con-
clude, I would just like to mention one problem: It is so easy
to overlook one group of risks when you are concerned with an-
We had talked here about the protection of pregnant women
in the NRC proposals. For the benefit of the group, there are
instructions to the persons who are in a managerial capacity to,
essentially, give a warning. The statement concludes that you
have to take risks. You should protect yourself against this,
just as you should not smoke, nor climb stairs during pregnancy.
In focusing on pregnant women, for example, the directive
ignores the fact that women who are not pregnant can also be ex-
posed to radiation. They will also have, in their children, a
markedly increased risk of leukemia. There is also, of course,
the question of whether the pregnancies are known or not.
The problem is not as simple as it might look, and it real-
ly requires some persons or groups who would have a direct mis-
sion for this purpose.
Dr. Morgan, Dr. Shleien?
Dr. Shleien. Just some comments on what has been said in
the last few moments, in an attempt to distill some of the
thoughts in the statements.
Everyone is in agreement that unnecessary radiation should
certainly be avoided. In speaking about particular groups that
have been mentioned, the Bureau of Radiological Health of the
FDA is carrying out some investigations relative to those you
79-767 O - 76 - 5
For example, the treatment of benign diseases with radia-
tion, a practice which has been decreasing, is now under invest-
igation, under contract with the Bureau at the Nation Academy of
The problem of mammography screening has also come to the
attention of the Bureau of Radiological Health, and its Medical
Radiation Advisory Committee has issued recommendations with
which we generally are in agreement.
Dr. Morgan. Would you state the recommendations for the
Dr. Shleien. The recommendations are:
"Women of all ages should receive annual physical
examinations of the breast and be taught breast
self-examination. For asymptomatic women the
first, or baseline, mammographic examination
should be performed between the ages of 35 and 40.
A second mammographic examination should be per-
formed in 3 to 5 years unless indications of in-
creased natural breast cancer risk for an indivi-
dual warrant more frequent examinations. Subse-
quent mammographic examination of women who re-
main asymptomatic should depend upon reevaluation
of the patient's personal risk status, the current
understanding about the efficacy of mammography,
and evaluation of radiation risks. After age 50,
annual or other regular-interval mammographic ex-
aminations should be performed."
Dr. Bross. May I say one thing on that?
I agree with the recommendations, but the programs are not
operating this way.
Dr. Shleien. I do not understand that.
Dr. Bross. The NCI, the National Cancer Institute, has
screening programs that do not operate according to those guide-
Dr. Morgan. Dr. Caldicott?
Dr. Caldicott. Being a clinician, I feel that we do prac-
tice defensive medicine and that we take x-rays in case we might
be sued sometimes; we take x-rays without thinking of performing,
sometimes, an adequate clinical examination and x-rays are not
monitored as to dose, particularly in the pediatric field. Some
children have packets and packets of x-rays, dose of x-ray and
radiation on each x-ray is not recorded and therefore we do not
know the amount of radiation that these children have had.
I think this is very important, not only may it be a risk
for those children later -- later in life. You must not forget
it takes from five to fifty or forty-five years for a cancer to
develop. Those children may live long enough to develop their
It may also affect those children's gonads, once again, the
testes and the ovaries.
The fact that was pointed out about fertile women in indus-
try also applies to fertile men in industry. I have here a paper
on thirty autopsies that were performed by the U.S. Transuranium
Registry. This is a registry that registers all men -- I guess
they are mostly men who have worked in the transuranium industry
for the last 30 years, 20,000 workers. This is the first report
of the first 30 autopsies of these people.
Eleven out of thirty died of cancer, which is an incidence
of 37 percent. The normal incidence in the population of cancer
in an autopsy population is 17 percent.
Three others died of suicide, and two of suspected suicide,
and almost all the rest died of arteriosclerosis of some form or
another and Dr. Martell has reported that arteriosclerosis may
be related to the deposition of alpha emitting particles within
the blood vessels.
This is hard data that actually workers in the transuranium
industry are dying from results of radiation.
Dr. Morgan. Could this report of these toxic cases be pro-
vided for the record?
Dr. Caldicott. Yes.
Dr. Morgan. Dr. Archer?
Dr. Archer. I have read that report which just has been
mentioned, and as an epidemiologist, I felt I could not make any-
thing out of it without knowing the age distribution of the pop-
ulation that one is dealing with. You cannot very well say what
the ratio between cancer and other diseases should be, even what
the causes of death might be, unless one knows the age distribu-
tion of the group.
Dr. Morgan. Dr. Richmond?
Dr, Richmond. I would like to suggest that perhaps some of
that information may be made available for the record of the
hearing, because that is not, as I recall, the conclusion of the
Dr. Caldicott. We do have the age distribution.
Dr. Archer. Pardon me, perhaps I did not make my point
clear. One has to know the distribution of the population from
which the deaths are drawn, not just the ages of the persons who
Dr. Richmond. I would like to make a general comment, too.
We may be missing our responsibility to convey basic information
to the audience.
We have a very varied, I am sure, group of people here. One,
I think we have to be very careful to state, where we are talking
about generalizations. We have been talking about the effects of
radiation on the developing embryo. This has been taught in reg-
ular biology classes, general classes, for decades. It is common
It is also common knowledge that the same biological causes
for the increased sensitivity also make the developing embryo
sensitive to many biological insulting agents.
It is not unique to radiation, I would like to make that
Two additional points: One, we have been aware of this. It
is factored into the standards. It is a generalization, a biolog-
I would also like to call attention to the fact that we
should not overlook the obvious, that is, if you are born today,
your lifespan is decades longer than people who were born earlier
in this century. Also, the statistics are at hand to show that
there have been dramatic changes for the better in infant mortal-
I suggest we do not cloud the issues with too many techni-
cal details and avoid the obvious things, that we have to be sure
the public understands.
Dr. Morgan. Mr. Barnett?
Mr. Barnett. Since we are still talking about population
groups which need extra protection because of extreme vulnerabil-
ity to radiation, we should not exclude the embryo and the fetus.
In this connection, our Bureau has a project at the Massa-
chusetts General Hospital which is testing the feasibility and
effectiveness of requiring that referral slips for abdominal
x-ray examinations of young women indicate the pregnancy status
of the patient. It will be interesting to see if this pilot stu-
dy results in a lower number of these examinations being ordered,
and perhaps an increase in the number of pregnancy tests as well.
One more comment on this type of protection. We feel it is
very important to educate the patient to volunteer information
about pregnancy to the clinician. One of the most important
things the patient can tell the physican is, "Doctor, I think I
may be pregnant." This will affect his decisions, not only
about the ordering of x-ray examinations, but also drugs that
may affect the fetus as well.
Dr. Morgan. Dr. Bertell?
Dr. Bertell. There are several things that have been inti-
mated, for example that some of the problems of the past are no
longer with us, and one of these problems is the radium dial
painters. In a booklet from the Bureau of Radiological Health,
it is estimated that these dial workers receive 12.1 rads per
year -- external, whole body dose of radiation .2^/
It was a tragic situation. Yet, if you look at the present
regulations for workers in the industry, while they are generally
under 5 rad, there are exceptions where they can go to as much
as 12 rad a year. It is permitted under certain extenuating cir-
I would just point out that this 12 rad permitted, on occa-
sion for nuclear workers is exactly the same exposure which was
so tragic in the radium dial workers.
Dr. Ellett. Could you straighten us out on the difference
between rads and rems? The radium workers were getting some-
thing like 12 rems, or 12 rads?
Dr. Morgan. I am not sure what the estimate of rad or rem
was to radium workers. I think it was in the neighborhood of 12
rem per year.
Dr. Bertell. Yes, for external gamma radiation, the rad and
rem are essentially the same. It is the external radiation in
the nuclear industry, which can go up to 12 rad, that is compar-
able to the 12 rem the radium dial workers received.
Dr. Ellett. The radium worker with internal alpha?
Dr. Bertell. Rem-wise it is the same, 12 rem.
Dr. Ellett. I thought doses for radium workers were in
terms of rem, were largely the same as at the start of their ex-
posure, and 12 rad radium alpha is 120 rem, not 12 rem.
Dr. Morgan. Mr. Jablon had a comment in reference to the
Mr. Jablon. There seems to be some question about just what
the effective doses were in the radium dial painters, and the
BEIR Report quotes Rowland's studies as follows: "No sarcomas or
carcinomas have been seen below the total accumulated mean bone
dose of 500 rads,"!/ and I would remind you that for an alpha em-
itter, 500 rads would be the equivalent of 5000 rems.
Dr. Bertell. For the sake of clearing the r^^cord, concern-
ing our previous discussion of the radium dial workers, I would
like to point out that my first statement referred to a yearly
exposure and I compared it to a yearly exposure of a worker in a
I think when Mr. Jablon responded, he talked in terms of a
cumulative dose over a number of years, and I think it should be
very clear that we were talking about two different measures.
Dr. Morgan. Are there any other comments? Dr. Sternglass?
Dr. Sternglass. I would like to add that it is widely be-
lieved that only a fraction of a millirem is the dose to the pub-
lic from nuclear plants, I have here in front of me the New York
State Health Department report entitled, "Environmental Radiation
Effects of Nuclear Facilities in New York State,"!/ in which, for
Indian Point Station, Unit 1, the annual average dose in milli-
rems, due to halogens and particulates alone for 1972 is given at
62 millirems at the boundary, and there are many other plants
that have levels on the order of 10, to 20, to 30 to 50 millirems
just due to the halogens alone.
Therefore, we cannot assume safely that when the plants are
such that everybody will be living within 50 or 60 miles of two
of them that the doses will be a tiny fraction of a millirem.
Dr. Morgan. We will take questions from the audience. Pleas
identify yourself, if you wish to make a comment.
Mr. Kepford. I am Chauncy Kepford. I live in York, Pennsyl
It has been stated there have not been controlled human ex-
periments with controlled radiation exposure. I disagree. There
are thousands of workers who have worked in the plutonium indus-
try. There was an entire division of U.S. Army troops that
marched off across radioactive ground immediately after an atom
bomb test in 1954 or '55.
Where are the health records of all these people?
Have they been followed up?
In the industry today, if one looks at the old Atomic Energy
Commission Reports of worker exposure, at least numbers 1, 2, 4,
5, and 6, the years 1968 through 1973, one finds a radically in-
creasing incidence of worker exposure and overexposure to radia-
tion. That is about 5 rem per year.
My question is, where are these follow-ups? The fact that
we have film badges that record exposure is one thing. Unless
the health data of these people that have been exposed to radia-
tion are followed, there seems to be very little need whatsoever
to record their exposure in the first place.
Dr. Morgan. Dr. Burr, perhaps you would give a very quick
Dr. Burr. I would just comment that we do have studies of
the health and mortality of workers. I will touch on this later
when I talk about some of the programs that ERDA has. We have
tried to take advantage of the information that is available.
There are other studies among which the Transuranium Regis-
try has been mentioned. This is a follow-up of plutonium workers
I will touch on that briefly, too.
That is probably sufficient for now.
Dr. Morgan. Dr. Bertell?
Dr. Bertell. Maybe Dr. Burr could answer this. If you are
not collecting data on chronic diseases, what do you expect to
see when you analyze the data on exposure? Is there any place at
all in industry where the medical record of the employee shows
the medical history of offspring, so that, should there be gene-
tic damage which shows up in the offspring, it will be noted? Is
any industry recording this so that it can be analyzed?
Dr. Burr. To take your second question first, T do not be-
lieve so. There are, of course, genetic studies associated with
the studies in Japan, and these include studies of the F-1 gener-
ation, but to my knowledge I am not sure there is anything that
would be comparable to what you have in mind.
The first question was on chronic diseases. Some informa-
tion of this nature is obtainable from the health and mortality
studies, I do not say it is available in an analyzed form at the
Dr. Morgan. Yes Ma'am?
Ms. Villastrigo. My name is Villastrigo. I am with the Wo-
men's Strike for Peace. Dr. Caldicott made a very important
statement here that I think the panel should deal with a little
bit more carefully in the next few hours. She said we are enter-
ing into a Plutonium economy that has only just begun.
One of the problems with the plutonium economy that has not
been dealt with is in areas where weapons production is going on
today in many parts of the country. People around those areas
are being exposed to radiation, including the testing areas like
Nevada. I would particularly point to the Rocky Flats area where
many people have been recently exposed to the very plutonium
economy we are talking about.
Rodger Rappaport in his book, "The Great American Bomb Ma-
chine," published some time ago, has dealt with this issue of the
weapons producing areas where it is absolutely dangerous to live
because of low level radiation.
I would like to know whether any studies have been made with
regard to the people who live in those areas and the levels of
radiation that those people are being exposed to and whether we
can ever get any kind of information about that?
Dr. Morgan. Does the panel care to respond?
Dr. Ellett. I will respond in part.
EPA is doing a special study for Rocky Flats, looking at
plutonium samples. They are also looking very carefully at cat-
tle who are slaughtered. They feel that cattle will have much
higher doses that people since they are putting their breathing
apparatus much closer to the ground. We hope from this study to
get some kind of information that is based on more than data on
the air around Rocky Flats and find what is getting into humans
and animals in that area.
Dr. Morgan. The gentleman in the yellow coat?
Mr. Swann. My name is Mark Swann. I live near some nuclear
plants in Pennsylvania.
I am wondering whether it is feasible to have small epide-
miological studies made around individual plant sitings. It seems
that we would not be involved with large programs and in the
event of accidents, small accidents, I am assuming, we would be
able to measure where we started from.
It seems to me if we spend money on trying to figure out the
mechanism of the radiation injuries and the damage we will just
waste time, and we should try to find out what kinds of things
I assume you would have to have a test area also.
Would it be fair to have the cost of such a program at least
shared by the nuclear interest who, after all, are making money
out of the enterprise?
I would like Dr. Bross to answer.
Dr. Morgan. We have on our panel some of the country's lead-
ing epidemiologists. I will give only one of you an opportunity
Dr. Bross. This is a feasible study and we have tried re-
peatedly to set it up in one place or another, including York and
There is a great interest in talking about these things.
When it comes to doing them, and more particularly funding them,
there is a sudden diminishment of this kind of interest.
You have heard of the very large sums of money that are go-
ing into a reactor program, breeder reactor program, and other
programs including high energy physics programs. For a very small
amount of that money you could run one of these health surveil-
lance systems, but nobody is interested.
Dr. Morgan. Dr. Collins, representing the labor union, I
would like to call on him to make a statement.
Dr. Collins. We have been hearing a lot about cost benefits.
We have radiation standards for workers which are considerably
higher than for the general public.
As I sit here today, I have a feeling of disquiet at 5 rem
per year upper limit. The members of the Oil, Chemical and Atom-
ic Workers, many of them workers in the nuclear fuel cycle, have
also a feeling of disquiet which they have made evident to us.
The National Resources Defense Council last September filed
a petition that the occupational exposure limit be reduced by
tenfold to .5 of a rem per year for workers under 45 years of age.
At that time, our union supported their petition.
At the present time, I would like to reiterate the position
of our union that the limit for whole body radiation should be set
by NRC at 0.5 of a rem in any year, 0.3 of a rem in any quarter,
and (age - 18)x0.5 rem for a long time accumulation.
The National Council for Radiological Protection, in noting
the enormous susceptibility of pregnant women to radiation, re-
commended that only half of 1 rem in any year be given to a preg-
Of course, under present standards she may very well receive
considerably more than that before she even knows she is pregnant.
At that time, the proposal to extend the NRC recommendation for
pregnant females, the NRC expressed it was unwilling to make a
special case for pregnant women on the grounds that it would be
sex discrimination, the right to privacy and depriving them of
the right to work.
The proposal, is that we extend the standard for pregnant
women to all workers. We agree with NRC that in terms of admin-
istering a plant, it would be very difficult to make a special
case for one particular class of workers. The reduction of radi-
ation exposure limits should be extended to all.
Our union is also very concerned about the internal emitter
problem. The very fact that alpha radiation is shortrange makes
it very dangerous inside the body. It has a radiological, bio-
logical effectiveness (RBE) of 10 and its short range leads to
heavy radiation of the body cells adjacent to the emitter.
Pure alpha emitters are very difficult to detect outside of
the body. The inaccuracy of bioassay monitoring is conceded by
everybody whose papers I have read.
We need tightened standards of airborne radiation.
Our union has no immediate proposal, but is studying air-
borne radiation hazards with the purpose of preparing definite
recommendations for new standards.
Dr. Morgan. Thank you.
y Archer, V.E., Gillam, J.D., and J.K. Wagoner. Respiratory
Disease Mortality among Uranium Miners. Annals of the New
York Academy of Sciences, v. 271. 1976:280-293.
2/ Mogliss, A. A. and M.W. Carter. Public Health Implications of
Radio-Luminous Materials. Bureau of Radiological Health.
Food and Drug Administration. Rockville, Maryland. July
y Committee on the Biological Effects of Ionizing Radiation,
National Academy of Sciences. The Effects on Populations of
Law Levels of Ionizing Radiation. Washington, D.C. N.A.S.
November, 1972. p. 132.
4/ Terpilak, Michael S., and B.L. Jorgensen, Environmental Radi-
ation Effects of nuclear facilities in New York State: v. 15,
no. 7, Radiation Data and Reports. EPA, July 1974:375-400.
Federal and State Responsibilities in Regulation.
Monitoring and Inspection
Ad equacy of Present Monitoring Programs
Dr. Morgan. Let us go on to the next question, question num-
ber five. What is the responsibility of the Federal and state
government for protecting the public and those various subgroups
from harmful amounts of radiation? Who is responsible for moni-
toring and inspecting the major emitters of low-level ionizing
radiation, and is this monitoring adequate?
Dr. Shleien. The Bureau of Radiological Health of the FDA
has the responsibility for the control and monitoring of electron-
ic products that emit radiation. This responsibility is defined
in Public Law 90-602. Although the Bureau is responsible for
various types of radiation, this conference is limited to ioniz-
Some of the standards that the Bureau has issued are: A
performance standard for diagnostic x-ray systems and their major
components; a standard for television receivers; a standard for
gas discharge cathode ray tubes; a performance standard for cabi-
net x-ray systems, including x-ray baggage inspection systems.
In addition to the issuance of standards, we also collect
and monitor information relative to medical radiation dose. Most
of the medical radiation dose information presently available has
been from the Bureau. Two programs in this area are being car-
One was the exposure to x-rays in the U.S. population, the
XES study!/; the other program is the NEXT study (National Expo-
sure to X-Ray Trends). This system monitors the means and the
extremes of x-ray doses from specific x-ray procedures.
In addition, we have a large research program involved in
the study of radiation bioeffects.
Some of the projects that we have supported under this are
the Alice Stewart study in fetal exposure. There is the largest
ongoing long-term exposure study on beagle dogs being performed
at Colorado State. The tinea-capita studies^./, particularly the
one carried out in Israel, is a large population and is an at-
tempt to extend the curve for dose response to lower dose levels.
Linked to this study is one in animals to determine the relative
carcinogenicity of radio-iodines versus external radiation.
The last aspect of our program that I would like to mention
is one dealing with improvement of radiation practices. I think
that I will leave that to Mark.
Mr. Barnett. Bernie mentioned one of the responsibilities
at the Federal level is to set standards for and monitor the per-
formance of machines that produce radiation. Complementing that
are our programs to improve the individuals who use those ma-
chines, upgrading the practices of physicians, radiologic tech-
nologists and dental personnel who apply x-rays to humans. These
programs are essentially educational in nature.
For example, we have developed a learning system for medical
students and residents in radiology which teaches them the basic
principles of radiation practice and which is now being used in
approximately one-third of U.S. medical schools.
Likewise, we have a training program for x-ray technicians
that is used in almost half of the 1100 or so x-ray technology
schools in the country.
We also have the responsibility to set guidelines or recom-
mendations which are gradually being published in the Federal
Register on good x-ray practices, including the use of gonad
shielding to protect patients from the genetic effects which were
alluded to earlier in the discussions.
We have recommendations underway on such issues as the irra-
diation of pregnant women from diagnostic x-ray examinations and
the use of quality assurance programs at medical facilities to
assure the best possible radiographs with the lowest possible
We also have a responsibility to educate consumers about
medical x-ray protection. Again, our programs to educate both
health professionals and consumers are complimentary to our pro-
gram of setting standards for and monitoring the performance of
Dr. Morgan. I would like to ask the question, when can the
Bureau of Radiological Health assure us that all the x-ray tech-
nologists are educated, trained and certified in the use of x-ray
equipment and there is similar knowledge and educational require-
ments of the medical doctor who prescribes these x-rays?
Mr. Barnett. We feel the improvement is taking place with
respect to the knowledge of the individuals who use radiation.
It is true that we presently lack uniform criteria for educating
and assigning credentials to either individuals who prescribe or
apply radiation to people, and some sort of consistent credential
standards are probably needed.
Several states now that license radiologic technologists,
use regulations that are often not compatible with each other, so
there is a need for uniformity there, too.
Dr. Morgan. I have been prodding the Bureau for years to
get on with this. Perhaps our next speaker from the Bureau will
indicate this job is underway, or maybe EPA will get on the job.
Dr. Ellett. I will get to that on your time, not mine. I
would like to respond to the listed question which is, what is
the responsibility of the Federal -state governments in the pro-
tection of the public from radiation.
I have looked at this. To some degree, it is very much a
mixed bag on who has the responsibility for what. I think the
public needs a greater understanding of what the responsibilities
I will start with the EPA responsibilities EPA inherited,
under a Presidential reorganization plan that set up EPA, the re-
sponsibilities of the Federal Radiation Council. I think the
Federal Radiation Council's responsibilities have been somewhat
misunderstood. Everybody says that their standards follow those
of the FRC. Well, FRC did not establish standards. FRC provided
guides to Federal agencies. They defined guides as a radiation
dose that should not be exceeded without careful consideration
for the reasons for doing so.
That maybe sounds strange now, but in the context of 1960,
when this was prepared, it was in a different era and I do not
think that it was particularly poor guidance at that time. There
may be some question of whether it needs updating or not. I am
not prepared to respond to that right now.
The FRC also recommended that all exposures always be ac-
companied by a benefit and that all exposures should be con-
trolled so as to be as low as practical. I think that most of
the arguments that are being made today on radiation standards
are not on the question of what the basic guides are or how basic
standards are established (by other agencies and by EPA), but
whether these standards call for doses that are truly as low as
To continue with what EPA's responsibilities are, under the
plan that set up EPA, they were given the responsibility for set-
ting both levels of radioactivity (quantities and concentrations)
and doses in the general environment. This standard setting
authority was created under the Atomic Energy Act and applies on-
ly to materials covered under that act. We believe where these
responsibilities come from (their legal basis) is very important
to what a Federal agency does. EPA can also set standards in
special situations like for drinking water. That responsibility
was assigned by Congress. In general, however, EPA has not set
radiation standards, rather it provides guidance to other Federal
Radiation standards are set by other regulatory agencies,
such as the NRC which provides standards for licensed material,
materials produced in atomic energy reactors, etc., that make
materials defined by the Atomic Energy Act.
ERDA is not thought of as a standard-setting organization,
but I assume they set as many standards as anyone in the country.
They set standards for all of their contractors. This is essen-
tially a part of their contracts.
ERDA has books of regulations that are known as their manual
chapters for radiation standards. This controls what the expo-
sures are for a large fraction of the occupational field. These
standards are within the FRC guides.
When we get down to state governments, the state situation
seems to be somewhat less clear. It looks as if states have some
responsibility for setting the level of exposure standards for
radioactivity, but one interpretation of the Minnesota decision
by the Supreme Court, in which the Supreme Court did not review
the appeal court's decision, was that the states were pre-empted
from saying anything about radiation hazards from materials cov-
ered under the Atomic Energy Act ( Northern State Power Company v,
Minnesota ) .
Control of natural radioactivity is the responsibility of the
states. In the past there has been a reluctance, perhaps, on the
part of the Federal government to look closely at hazards from
natural radioactivity. The only Federal guidance out is on radon
exposures to workers in underground uranium mines.
There was a second part of this question, who is responsible
for monitoring and inspecting the major emitters of low-level
radiation? Is this monitoring adequate? It asks for various
agency representatives to describe the number of persons and bud-
get devoted to these responsibi 1 ites
EPA has the responsibility, that was transferred by law from
the Public Health Service by Executive Order to collate, analyze
and interpret data on environmental radiation levels. We obtain
the data from NRC and from ERDA that they receive from their mon-
itoring programs, which I am sure they will describe to you.
We have some information from the states published by EPA.
EPA also has its own monitoring network called the Environmental
Radiation Ambient Monitoring System and it performs work in its
laboratories for the states and for its own special projects on
what environmental levels are.
This is not a large program, but it is a major program in
terms of EPA radiation funds. Our '77 budget calls for 40 posi-
tions being devoted to this type of monitoring, collation and
publishing of the information on background radiation and $760,000.
This is roughly a quarter of our total budget for radiation in the
Of the $760,000, about $350,000 is for our environmental
monitoring system which, by the way, is not at every reactor but
it is in places in the general environment. We usually pick sam-
pling stations so they are fairly close to some nuclear facility,
but the system covers large metropolitan areas as well, and other
selected places, so we have a large geographical distribution.
We also are doing about $500,000 worth of special field stu-
dies this year. This program is concerned with places where an
environmental problem has been identified.
We are also spending $225,000 on monitoring of non-ionizing
radiation. This is the only Federal program for non-ionizing rad-
iation regulation in the country. I will not go into details of
Dr. Morgan. The last part of the question was, is this ade-
quate? Do you need more money in EPA, or is this an adequate pro-
Dr. Ellett. I am not in the position to discuss adminis-
trative budgets. I think, really, the panel and the public have
to decide what is adequate and what is not adequate. We have
twenty active stations to sample radioactivity in air at the
present time; another fifty-four on inactive status.
We have twenty stations in the country that look for pluto-
nium and uranium particles in the air. We have twelve that look
We sample a grand total of fifty-five surface water sources
and seventy-six drinking water sources, and, in conjunction with
the states, we also look at the interstate carrier systems, water
supply to trains and things like that, up to a level of two hun-
dred samples per year. It does not seem like an overwhelming pro-
Dr. Morgan. I dare say some of the panelists later will
have some opinion on whether it is adequate.
We have now heard from the Bureau and the Environmental Pro-
tection Agency. We will now hear from NRC.
Dr. Mattson. NRC gets its authority for regulation from
three basic places, the Atomic Energy Act of 1954, the National
Environmental Policy Act of 1969 and the Energy Reorganization
Act of 1974. Our responsibilities are very broad and quite
unique, I think, in Federal Regulation, as to the detailed
authority granted to us in controlling the users of source mater-
ial, byproduct material, and special nuclear material, as they
were defined in the Atomic Energy Act. These responsibilities
include the safety of facilities handling these materials, the
exposure of the public for normal operation of these facilites,
the exposure of workers within these facilities, the use of by-
product and special nuclear materials as radioisotopes in nu-
clear medicines and industrial applications.
Because our authorities are rather broad with these three
types of materials, we also run into interfaces with other ag-
encies. In that regard, we have consistent regulations with
the Occupational Safety and Health Administration of the Depart-
ment of Labor, the radioactive materials transportation functions
within the Department of Transportation, the Food and Drug Admin-
istration, the people seated on my left, the Environmental Pro-
tection Agency, and the United States military.
Of most importance to today's discussion is our responsi-
bility in regulating the nuclear fuel cycle, the production of
electricity from uranium. The lines of responsibility there
are very clear. As soon as uranium ore leaves the mine it comes
under our regulations and stays there, right through its use,
its reprocessing, and its disposal as waste.
We have regulatory responsibility for the material from the
time it leaves the mine.
Some of our responsibilities have been delegated to the
states under an agreement states program spoken of in our regula-
tions. Approximately half the states in the United States parti-
The kinds of authority that are delegated are those pertain-
ing only to byproduct materials and source materials of less than
a critical mass. Special nuclear material is kept for Federal
These regulatory authorities go to the states, when a pro-
gram proposed by a state is approved by NRC. One of the base re-
quirements of those programs is that they have compatibility
with the Federal regulations.
As has already been said, there is pre-emption by the Fed-
eral government of radiation standards setting for byproduct,
source, and special nuclear material.
Now as to how our system works. Basically, our system of
regulation is divided into four functional areas. We write stan-
dards in the form of regulations. Title 10 of the Code of Fed-
eral Regulations contains NRC regulations.
We license individual facilities as they fall under these
regulations. We do a case-by-case review for each new reactor,
processing plant, uranium mill, whatever.
We inspect the operation of those facilities against li-
censed conditions which are specified as a matter of contract,
if you will, with the Federal government. "Contract" is not the
right word; I should explain that.
License conditions are a matter of law, i.e., enforceable
under law, within those license conditions are contained the pri-
mary requirements for monitoring by our licensees. That is,
rather than the Federal government monitoring each facility case-
by-case, we require as a matter of license, for each facility,
that the licensee do the monitoring. We require effluent moni-
toring, environmental monitoring, and monitoring of the people
who work in the facility. All of this monitoring is specified
along stringent lines contained in our regulations.
In addition, we inspect the operation of each facility
against its license conditions to see that the licensee is doing
the monitoring. In addition we audit in the sense of independent
measurements to confirm licensee measurements. Not at all facil-
ities all of the time, but as a sort of spot check.
Our success with monitoring has been very good. I might
note that there have been a number of states who have become in-
volved in third-party monitoring, if you will, in addition to
the licensees and the NRC. States have said they want to keep
track of the emissions from various fuel cycle facilities. We
encourage that, in fact, we have a program for some partial
funding of that through the Federal government.
It has worked very well in the past, it goes back some
twenty-five years, way back to Shippingport .
As a summary on the budget question that has been raised,
we have, in fiscal '76, some 2,200 people in the Nuclear Regula-
tory Commission with a budget of $218 million this year,
I did leave out a functional category in that regard, con-
firmatory research. We do some research at NRC of a confirmatory
Unless there are further questions on the budget, I would
just as soon leave it at that.
Dr. Morgan. Do you consider that your program is adequate?
Dr. Mattson. For now, yes, sir.
Dr. Morgan. Dr. Caldicott?
Dr. Caldicott. As a pediatrician, and if we proceed with
nuclear power as it seems that most people around this table
think is a good idea, can you guarantee that in a hundred years
or 500 years the standards that you are talking about now will
be conformed to, both in America and throughout the world, be-
cause I do not come from America?
Dr. Mattson. The operating life of the facilities we are
licensing with this particular standard is over 30 years. You
are talking about waste management, is that what your concern is?
Dr. Caldicott. Waste management from breeder reactors.
Dr. Mattson. We have no standards for the licensing of
breeder reactors at the moment.
Dr. Caldicott. Are we going to have standards of radiation
acceptable to the population when breeder reactors come into be-
Dr. Mattson. I do not believe we have licensed a breeder
Dr. Caldicott. Are we planning to
Dr. Mattson. There is one that has applied for a license.
Dr. Caldicott. Are we planning to go ahead with the breeder
Dr. Mattson. I think we talked about that this morning and
the role of NRC in that regard to make independent judgments re-
garding the safety and environmental impact of reactors for which
people file an application. That is quite a different question
than are we going ahead with the breeder reactor program.
Dr. Morgan. Dr. Bross.
Dr. Bross. I would like to start with the statement which
was made by Dr. Mattson and others, in which he said, in effect,
there is no human data on the low-level effects, genetic effects.
We have a Tri -state Survey and we have information and the
results in the children of their various health hazards. In this
connection, I might add parenthetically, in connection with EPA's
comment, following up this particular group would almost be a di-
rect answer to the specific kind of study it asks for.
The point is, if the members of the regulatory agency sit-
ting here before you are going to say, there is no data -- this
is not a question of science, it is a question of fact: is there
data or no data?
There is in our files, in our records, material in comput-
able, usable form. It is a matter of fact, whether there is data
on this or not. There is data. What we have here is a simple
refusal on the part of the regulatory agencies to look at the
data, to think about the data, to use this data. I publicly chal-
lenge the NRC to set up an adversary science hearing, I will come
down to argue this point. They can present any experts they wish
against me or against our side. We will thrash out whether or
not we can show clear-cut genetic effects from low-level radiation
on the order of 1 rad.
We will carry on this debate so members of the public can
understand what we are talking about, not esoterical ly .
Now I think, if we don't use the data we have, it does not
really do much good to set up an elaborate system for collecting
data. I have been in public health for 25 years, all the way
back to the smoking and lung cancer issue. It was always: We
need more data. We don't do anything about cigarettes. We are
going to get more data.
I do not think this is the way to solve the problem. I do
not think obscuring the issues by bringing in cost factors and
making a big mess of things is helping, either.
There are human beings exposed to risk. The question is:
Are they going to have diseases, are they going to die, as a
result of this kind of exposure?
That is the issue. It does not involve a lot of costs. The
question is: Are there a lot of people who are going to get
killed? If so, we do not want to do it.
Let me say that I strongly support a program for getting
better data and I think this has come up several times for low-
level radiation hazards.
I support it with the intent that it is going to be used to
do something about these hazards and not as a method of simply
delaying public action. We know what to do right now.
Dr. Morgan. Dr. Mattson, you have been thrown the glove.
Will it be pistols, or will it be swords? Do you care to re-
79-767 O - 76 - 6
Dr. Mattson. First of all, I do not think I said that there
were not any human data. I think that the conclusions drawn from
the data were not hard evidence of a direct link between low-lev-
el radiation and health effects in man. We have heard people
discuss both sides of that issue all day today.
I assure you, Dr. Bross, you need not throw down a gauntlet
to have an ear in my office.
Dr. Morgan. He has suggested that there be a public hearing.
Maybe you might consider that also.
Dr. Mattson. There are procedures for obtaining formal hear-
ings by the NRC. I am sure you are aware of them. They are called
Petitions for Rule-Making and Requests for a Hearing. I certain-
ly, as an individual, am not empowered to grant such a request on
behalf of the Commission.
I repeat, my telephone line is open, my door is open. If you
want to discuss this subject, bring in the data. We are there to
Dr. Morgan. Dr. Burr?
Dr. Burr. I am Dr. Burr from ERDA. I will comment briefly,
because ERDA's role has been touched on already.
ERDA does retain the responsibility for its contractors and
our environmental monitoring budget for ERDA contract operations
is approximately $6 million a year. This involves about 450 people,
including both ERDA and contract personnel.
The data is gathered, reviewed and published. Dr. Burr has
a set of information from the recent environmental monitoring pro-
gram that we would like to leave with the committee.
Dr. Morgan. Thank you. Dr. Burr. Dr. Burr, we will receive
it. We will now hear from Dr. Archer in reference to NIOSH.
Dr. Archer. The major governmental agencies dealing with
radiation have already been heard from. There are three others
that have some concern.
One is the Mine Enforcement and Safety Administration --
MESA. The other two are the twin agencies created under the Oc-
cupational Safety and Health Act. They are the National Insti-
tute for Occupational Safety and Health and the Occupational
Safety and Health Administration, NIOSH and OSHA.
MESA, the Mine Enforcement Safety Administration, gets their
authority from a special metal mine act which gives them author-
ity to control all hazards in mine operations. It is mines they
are concerned with, and they have a very active program for mea-
suring the concentrations of radioactive material in essentially
all mining operations. They concentrate on radon daughters in un-
The law which created NIOSH and OSHA has provided very wide
powers for these two agencies: for NIOSH to investigate prob-
lems and OSHA to enforce standards. They have very wide powers
to look into and control occupational hazards. However, the law
also puts in an exception, it excepts those situations where au-
thority has been delegated to other agencies.
In this case, nearly all of the authority for radiation pro-
tection has been delegated to other agencies; both NIOSH and OSHA
are concerned very little with it. The one study that NIOSH re-
tained was the study of uranium miners. We retain this for his-
torical reasons. The Public Health Service got into that study
at a time when none of the other agencies were interested in it.
Dr. Morgan. Thank you. Dr. Bertell?
Dr. Bertell. I think we are talking here about protecting
the health of the public and when I think about protecting the
health of the public, the first thing I wondered about is how
healthy are the people?
I look back at the OSHA form which has to be filled out by
employers. If you have an occupational ly-related illness, you
have to report this at least in the state of Vermont within 72
hours. Unless you received more than a 50 rad dose and got im-
mediately sick from radiation, that is, within 72 hours, there
is no obligation to report radiation-related disease.
I read Dr. Lassiter's report^/ -- he is from OSHA. He gave
this report at a meeting of the New York Academy of Sciences in
March 1975. He said the OSHA reporting form from employers picks
up 2 percent of the medically-diagnosed, occupational ly-rel ated
disease, 2 percent. This is not watching people. This is not
seeing what is happening to the people in the occupational situ-
Reports in industry need to be kept only five years. Again,
you have eliminated a whole slew of diseases.
You do not have a cumulative record that moves with the
worker. If he changes employment, he starts all over again.
We say we are very interested in people exposed to medical
radiation. We have done several extensive studies on the doctor,
the physician radiologist. Dr. Vilma Hunt_/points out that no
studies have been done on women who are the x-ray technologists.
We brought up Women's Lib a few minutes ago.
I think there is something radically wrong with a monitoring
program when we do not look at the people and say, are they sick?
I just finished reading a report on the uranium mineworkers.
It says in this group of 25 there were no cases of lung cancer.
They told you nothing else about the people, are they sick, what
is the matter with them, have they died of anything?
I just think that the important issues are being lost in a
whole lot of paperwork.
Dr. Morgan. Thank you. I think it is very important to
have this on record. Certainly, many of us have been made aware
of this statute of limitations for example, it does not provide
adequate protection. Dr. Richmond?
Dr. Richmond. I would like to respond to that last comment
that was made. I believe you meant plutonium workers, not uran-
ium workers .
Dr. Bertell . Yes.
Dr. Richmond. I know of at least three places where that
information is published, including the open literature and the
details are given as to the causes of death.
I would like to also mention that that particular group of
individuals was studied since 1944, during the war years when
the first nuclear weapons were developed. These people were stu-
died and they are still being studied today.
For the record, this is a published, scientifically reviewed
document. Available evidence -- I encourage you to read it.
Dr. Bertell. Could I have the reference?
Dr. Richmond. I think I have a copy with me. I will give
it to you personally.
Dr. Bertell. Thank you.
Dr. Morgan. Could you provide this for the record also?
Dr. Richmond. I would be very pleased to. (See Appendix)
Dr. Morgan. Dr. Mattson?
Dr. Mattson. May I interject briefly on something Dr. Ber-
It should be clear for the record that people who are ex-
posed to radiation as a matter of their work are monitored with
devices that measure radiation. We do not depend on workers re-
porting to their management they have been sick. We require un-
der law that they report exposure to radiation.
I believe that is the case for other agencies as well. The
2 percent does not apply to radiation.
Dr. Bertell. Excuse me. There is a differnece between re-
porting how much radiation you are exposed to and what diseases
later occur, to see if there was a correlation. Those are two
Dr. Morgan. Dr. Archer?
Dr. Archer. Perhaps I could add a bit of clarification to
this matter of reporting.
A number of state occupational laws do have provisions for report
ing diseases related to occupation. Most of the states have simi
But, as a rule, about the only conditions that are reported
under these laws are accidents, because they are obviously rela-
ted to work. Sometimes acute diseases, things that happen right
on the job, are reported. Any chronic disease or long-delayed
diseases are rarely or never reported. The primary reason for
this is that nobody recognizes them as occupational disease. Even
if a doctor thinks a chronic disease might be occupational ly re-
lated, he cannot be sure of it.
The only way that one can really be sure of the etiology of
these diseases is through epidemiological studies. The method of
reporting occupational disease for chronic or long-delayed dis-
eases just does not seem to work.
Dr. Morgan. Dr. Caldicott?
Dr. Caldicott. Do any of those studies show people with ter
minal diseases injected with plutonium?
Dr. Mattson. May I respond to that?
Dr. Morgan. Dr. Mattson?
Dr. Mattson. People who work with radioactive materials
such as plutonium which are dangerous as internal emitters are
working in an environment where the routine operation is one of
total confinement of those internal emitters. Only in unusual
circumstance such as maintenance or accidents or incidents do
the internal emitters become airborne within the working envi-
When that happens, the workers put on respirators. They
are monitored by health personnel very closely when that happens.
For example, swabs of mucus, or internal measurements are made.
Dr. Morgan. Dr. Caldicott?
Dr. Caldicott. When you put people on respirators, it does
not necessarily remove the plutonium particles nor the bronchial
swabbing or bronchial lavage. It may remove some; it may not re-
move all of it.
I would like to address myself to the responsibility of the
Federal and state governments for protecting the public. We are
about to embark on, it seems a plutonium economy, not just now,
but for future generations for hundreds of thousands of years.
By the year 2020, we will have produced 30,000 tons of plu-
tonium. There would be 100,000 shipments of plutonium per year
on the highways of the United States, it is predicted. We know
that plutonium is one of the most toxic, carcinogenic substances
we have ever known, such that a millionth of a gram will produce
I would suggest that the responsibility of the Federal and
state government, is to work out regulations and reports right
now, but we cannot predict what future generations and societies
will do with this plutonium and what will happen to it, and what
v/iU happen to future generations of children and also that
is just the year 2020, what about the year 2050, what about the
year 3000, if we keep on with nuclear power?
I would suggest, as a pediatrician that this is the biggest
public health hazard we have ever known, bigger than malaria and
smallpox because the potential damage to the genetic building
blocks of life is immense.
I would suggest that the responsibility of the Federal and
state governments is to stop producing nuclear power plants and
plutonium now. We are already contaminated with plutonium, all
of us, from fall-out. We do not know what the danger is yet.
We need large epidemiological studies. We do not know of
the dangers to other generations. Is it up to us to prove it
is dangerous or for the industry that wants to proceed to prove
that it is safe?
Dr. Morgan. As Chairman, I would not ask the panel to re-
spond to this. I am sure that it would take the rest of the
week to adequately respond, but we have promised the audience
that we would give them a chance to make a comment or ask a
Mrs. Brackman. I am Selma Brackman, a coordinator for some
sixty-odd peace organizations in the United States. The name of
our coalition is the Coalition for International Cooperation and
Over the last year, we have addressed ourselves to a peace
ballot on which we have two propositions that will be afforded
to every major candidate and one of them says that the United
States should enact stringent legislation to prevent pollution
of the oceans and the atmosphere, and the second is that sub-
stantial public funds should be used to develop nonnuclear ener-
gy, including solar and geothermal energy and where possible in
cooperation with other nations.
Now the question this morning was, how much authority should
the states have as contrasted to the Government, the Federal Gov-
As a coordinator for another coalition in Vermont, we found
that Vermont is the first state in the United States to say to
the Federal government, we reserve the right to veto the restric-
tions or the permission that the Federal government has given for
the siting of a new nuclear reactor.
I know Vermont quite well, having lived there for a number
of years during the summertime and the Yankee Vermont power re-
actor has had numerous blasts, and some of the pontif ication that
goes on at this table wherein some of the gentlemen state, we
will not allow it -- well, it has been allowed. Not by you, not
by me, not by anybody, but it just happens.
These overdoses that come out, we do not know for ten or
twenty or thirty or forty years what is going to happen to the
people who live, what is going to happen to the workers there.
None of this comes out in the newspapers.
I think it is high time that some investigation to that ef-
fect is made, that the very real problems that are not even ad-
dressed here to the effect that the radiation problem occurs and
there is nothing we can do after a certain point.
We are not all omnipotent, and we must realize that.
Dr. Morgan. Mr. Goodman.
Mr. Goodman. It so happens that the Governor of Vermont
asked me to come up and advise him about that plant when the ap-
plication was first filed, and I told him in my judgment it was
the wrong kind of plant and at the wrong place at the wrong time.
It was the State of Vermont that passed the regulation to
permit central Vermont to sell the bonds to proceed with the con-
struction of the plant, so I say to you the responsibility is not
just in the Federal government.
Dr. Morgan. Thank you. Other comments?
Mr. Laitner. My name is Scott Laitner.
There has been an increasing number of statements suggesting
that we do not know all that much about the effects of radiation,
particularly at low-level doses and dose rates. It seems to be
a case where the more we find out, the more kinds of cause and ef-
fect relationships there seem to be.
This raises a question, I think Dr. Morgan pointed it out
very well. The object seems to be that we should allow minimum
exposure to radiation regardless of the source. My question now
becomes, Why is it, looking in terms of manmade radiation or man-
produced radiation effects; Why is it we always seem to be look-
ing at nuclear power as given, rather than determining how we can
do without nuclear power, recognizing the potential dangers?
Why is it that regulatory agencies always seem to accept
these things as given, whether in terms of medicine, or in terms
of power production, and then try to balance the cost-benefit ra-
Dr. Morgan. We will assume that Dr. Mattson would feel
that this has been answered or has been responded to frequently
in the open literature. Do you have any further comments?
Dr. Mattson. I would challenge that there is such an assump-
tion by the Nuclear Regulatory Commission. NRC is an independent
regulatory agency charged with licensing the use of byproducts,
sources or special nuclear material. If there is no nuclear po-
wer industry, we do not license anything.
If people propose facilities, and they are safe, we license
Dr. Morgan. The next person?
Ms. Salzman. My name is Lorna Salzman, and I am Mid-Atlantic
representative of Friends of the Earth. I have two brief ques-
tions. The first is: Why is the assumption made, in setting
radiation standards, that workers are not part of the public?
Worker standards for radiation exposure are different from the
public exposure standards.
I assume the workers in the population do reproduce with non-
workers, and that therefore the genetic risks to them from radia-
tion would be reflected eventually in the population at large.
This seems to be an inconsistency in the Federal standards and I
would like to have an explanation.
Second, if the risk is as minimal as you say, why are the new
proposed EPA standards considerably higher for workers than the
public? Why not make the standards for workers the same as for
Dr. Morgan. Dr. Richmond, would you respond?
Dr. Richmond. I am not at all certain why you are directing
the question to me.
Ms. Salzman. Perhaps I am in error. I believe you are the
one who played down the risk to workers.
Dr. Ellett. I would like to respond to the EPA part of it.
Dr. Richmond. I will answer the question, though.
Dr. Morgan. Would you like to give a brief response?
Dr, Richmond. Very briefly, yes.
Especially in regard to the first question you asked, there
is a difference purposefully built in the regulations and standards
to make the distinction between the worker and the person in the
general public because, as is true with any endeavor, there is
some risk associated with any kind of employment. That is a well-
There is a biological principle here: there is no such thing
as a free lunch. Everything you do has a risk associated with it.
The assumption is that the radiation dose associated with em-
ployment is relatively higher than that which you would expect the
general population to assume. There is also a statistical argument
that the lowering of the standard by roughly a factor of 10 al-
lows for differences in age, et cetera, in the general popula-
tion, because the people who are employed are generally in bet-
ter health and are given physical examinations. So that there
is a reason, obviously, behind this.
I hope you did not get the impression that I am minimizing
risk from radiation.
Ms. Salzman. I got that impression.
Dr. Richmond. My feeling is that we have been extremely
fortunate. In fact we realized that early in this century. Be-
cause of things like the young ladies who painted the radium
dial watches, these adverse effects were reported in the mid-
1920's, decades before plutonium and actinides were discovered.
We realized fully -- this was before my time, obviously --
that there are serious effects associated with radioactive ma-
terials. I think that early perception of the danger has been
one of the things that has kept the record extremely good be-
cause there is no documented evidence of any plutonium occupa-
tionally associated disease.
Ms. Salzman. Would you say there is a gene flow between
the workers in the industry and nonworkers?
Dr. Richmond, I do not think that requires an answer.
Dr. Morgan. Dr. Ellett, you had a response?
Dr. Ellett. Could you reword your question? I think you
have things upside down. When we are talking about the proposed
EPA regulations, they are lower than that for occupational ex-
Ms. Salzman. Not for reprocessing plants.
I believe it is 75 millirems. Is that the dose for indi-
vidual workers in reprocessing plants?
Dr. Ellett. As far as I know, EPA has proposed no regu-
lations for occupational exposures at all. They have proposed
limits for people living in the vicinity of nuclear facilities,
a uranium fuel cycle that would include reprocessing plants.
These limits are quite a bit lower than the 500 mrem/y indivi-
dual limits of 170 mrem/y limits for populations that we have
been using so far.
The reason that these are lower is that these are based
on cost studies that show that these limits are practical.
I do not want to leave the impression that EPA limits are
higher. They are the lowest of any limits that have been pro-
posed. I must point out that these are proposed limits, not
Mr. Augustine. My name is Bob Augustine. I am the staff
researcher for the National Intervenors. We are a coalition of
1 56 citizens ' groups .
There are a number of things that I am concerned about be-
cause we have not dealt with them today. They come under the
purview of this conference.
First of all, in connection with the NRC standards, they
apply only to what are called planned releases and not to un-
planned releases, which are accidents and leaks. We do not know
how many curies have been released in unplanned releases. If it
has been anywhere near approaching the figures that have been
released in planned releases, we have only been monitoring half
The licensee monitoring program, which is what the NRC
has, was not any good at Kerr-McGee, not any good at Shipping-
port, and its spotcheck program has not revealed these. What we
are going to do about these, I do not know.
Maybe one of the things we can do is improve the penalties.
If you look at the penalties for breaking all of the rules, they
are not sufficient deterrents for that kind of action.
The NRC standards also do not take adequate account of the
ability of animals and plants to reconcentrate the materials
that are released in nuclear power plants.
There have been studies done that show that these factors of
reconcentration by animals and plants would be thousands of times,
40,000 times more than the concentration in the water.
These things are not taken into account in the setting of
There is a little bit of study done on the cow-milk path-
way and a couple of others, but there are literally thousands of
pathways where nuclear emissions from nuclear plants can get into
human bodies. With licensee facilities, the lack of health phy-
sicists is a scandal. The inadequacy of the film badge program
for protection of workers is another one.
If you are a worker and you work near a pipe that has a
crack in it and there is a stream of gamma radiation that does
not hit you in the chest, the badge won't show it and you won't
know until the cancer develops.
When you talk about monitoring adequacy, what we need to
know is what is being monitored and how extensively, how many
monitors there are around each plant, and what do they monitor?
We have to check on all of these things. What would the
improvements in the monitoring system cost? Who would have to
pay for them?
Furthermore, I would like to know, since we have some FDA
people here, if radioactive contamination of fish and other foods
occurs, what confidence can we have that the FDA would be able
to detect it?
Dr. Morgan, I don't think we can answer all of these ques-
tions. I will give Roger a minute to expound.
Dr. Mattson. I will be brief and go through these.
Planned and unplanned releases are all reported to the NRC.
Mr. Augustine. They are not monitored. Unplanned releases
occur where you do not have a monitor.
Dr. Mattson. If it is a nonaccident situation or abnormal
occurrence in the operation of the facility, that occurs through
the same effluent stream that the planned release would occur.
As for the unplanned release in the case of an accident, there
are monitoring capabilities for that, emergency monitoring capa-
As to the question of fines, I think that history shows in
recent years the stiffer application of fines, perhaps somewhat
differently by the Nuclear Regulatory Commission. I really was
not prepared to address that today, and maybe there is some food
for thought in what you say there.
As to the question of reconcentration of radionuclides by
the various pathways and fish, we do consider that. Those are
considered in our calculation models.
You mentioned thousands of pathways and we only treat two
or three. You are basically right, but we treat more than two or
three, that is an oversimplification. In order to choose the
dominant pathways there have been literally thousands of path-
ways studied by which radionuclides leave facilities and reach
Some of the research ongoing at ERDA continues to address
these. We have confirmatory research at NRC continuing to ad-
dress these pathways.
As to the lack of health physicists, we recently changed the
regulatory guidance on the qualifications of health physicists on
all operating facilities in the nuclear fuel cycle, in fact, all
the licensed facilities under the NRC purview.
Dr. Morgan. It is not just applied to power reactors?
It applies to the reprocessing plants?
Dr. Mattson. Yes, sir.
As to film badging being inadequate -- maybe the Bureau of
Radiological Health would like to chime in here. We are about
to have a public meeting on film badge qualification testing,
something that is needed to be done.
People have seen the need for this for years. They have
tried a number of routes. The most recent try was half a dozen
years ago. The data are now conclusive. It is not working as
well as people hoped it would. We are talking about indepen-
dent qualification laboratories of some sort, working with BRH
and the National Bureau of Standards.
The things that you mentioned concerning monitoring, the
radionuclides you talked about, are all monitored. I do not have
them all written down here. I cannot repeat them. I recognized
them as you read them.
We have a definitive set of guidelines on environmental and
effluent monitoring for nuclear power plants and a similar set of
guidelines is under development for fuel cycle facilities. We do
not now have an operating commercial reprocessing plant in this
country, but we have recently changed our regulations with regard
to the gathering of reporting and monitoring data for that kind of
facility as well as other fuel cycle facilities, if that is the
point you are making.
Dr. Morgan. Another question.
Ms. Allen. My name is Judy Allen from Virginia.
I am particularly concerned with the shifting state and Fed-
eral responsibility, what may be an illusion of protection.
I would ask Dr. Mattson about the total care that you say is
given in the nuclear fuel cycle. A Charlottesville Council -per-
son wanted to inquire about transportation of nuclear waste and
contacted the state of Virginia, and was told by the state of Vir-
ginia that these waste transport vehicles were monitored by the
NRC and monitored by DOT.
We contacted NRC and were told that your responsibilities
stop at the utility site border, that you no longer are respon-
sible for that transportation, so there is no monitoring.
In fact, at the Department of Transportation we were told
that they set standards for the 30-foot drop container but that
they also do not do monitoring.
Could you give us some idea of the kind of protection that
we are afforded in the transport period when the NRC and the DOT
seem not to monitor, but the state seems to think they do?
Dr. Morgan. Dr. Mattson?
Dr. Mattson. The Department of Transportation is right.
They do certify the container for transport and the criteria
against which they certify it are contained in their regulations.
The NRC is also right. Once it leaves the site boundary it
is outside of our jurisdiction. But that does not mean that in
between nobody is watching it.
As far as the licensing of the facility, the applicant has
to state to the NRC "this is how I am going to take care of my
wastes, as they are generated year by year. We are going to ship
them. I am going to send them down the following railroads, down
the following highways, they will be received at the following
reprocessing plants, and so on."
That statement by a license applicant is reviewed by NRC
from a safety and environmental standpoint.
Dr. Morgan. Dr. Caldicott?
Dr. Mattson. May I finish my answer?
NRC's monitoring of that shipment would occur as the shipment
left the facility, probably under license requirement on the own-
er or operator of the facility and then monitoring would pick up
again when it is received at another NRC licensed facility, which
it always would be.
Dr. Caldicott. Could I ask, I believe there have been three
autopsy series in the transuranium workers. The first 30 have
been reported; have the others been reported? If not, how could
we obtain this information, because I do think it is relevant to
Dr. Burr. Dr. Marks, our pathologist, tells me 50 have been
If you are interested in learning more about the others, of
course, they will be reported. He might speak to you at the break,
if you 1 i ke.
Dr. Morgan. I will take just one more question from the
Mr. Mi Herd. My name is William Mi Herd. I am from the
Center for Science in the Public Interest.
I do not know whether the questions this afternoon will oc-
casion any further discussion of the hot particle controversy. If
they don't, it would be very unfortunate to leave Dr. Richmond's
remarks as the record of that controversy.
In particular, I am referring to his characterization, for
instance, of the Biophysical Society's comments on the NRDC's
(Natural Resources Defense Council) position.
The AEC and ERDA erroneously characterized the Biophysical
Society as agreeing with their position that the standards should
not be changed, whereas in fact only one of the six reviewers
so stated in their comments. Four others agreed that the evi-
dence is available that will lead to a lowering of the standards.
Two of them actually said the standards should be lower. Two
others made other estimates of the degree to which the standards
should be lowered, agreeing only that the NRDC in asking for a
reduction by 10^ may have been exaggerated. But one of their own
estimates suggested a lowering of the standard by 10^.
Nonetheless, I think that the discussion this morning is a
gross mischaracterization of the state of the controversy. Since
there are so many here, including Dr. Richmond, who are involved
in this controversy, if that issue comes up again, I think it de-
serves a much more thorough discussion.
Dr. Morgan. In view of the lunch hour that already has
passed, I would like to indicate that after lunch we are going
to make some minor modifications in the order of questions, but
certainly we will discuss the role of the independent scientific
community and what recommendations are to be made that are speci-
fic for Congressional hearings and for action.
Dr. Morgan. It has been requested that we get back for a
few moments to question 5 and focus particularly on the last part
of that question.
I directed it to one or two of the panelists. The question
is, namely "Is this monitoring adequate?"
Seymour, I am not sure that you responded to that. Do you
feel that as far as the uranium mining and so on are concerned,
is the monitoring adequate, are the funds adequate?
Dr. Archer. Yes, I think the monitoring and the funds are
adequate to control the situation reasonably. As far as uranium
mining in particular is concerned, it is only recently that the
standard has been fully enforced. We are gradually getting down
Now that it has reached, and it is kept reasonably well, I
think that the risk in the future will be greatly reduced and
probably less than the risk of cigarette smoking.
Dr. Morgan. As far as the Bureau of Radiological Health is
concerned, I believe its attention is directed more at the manu-
facture of devices such as color television and so on. I believe
I asked the question before. I will repeat: Do you feel that
the monitoring of such devices is adequate from your point of
Dr. Shleien. As you mentioned, we do have a compliance pro-
gram. Under Public Law 90-602, that is an enforcement program.
I think the question might relate more to the monitoring of doses
of radiation during medical procedures.
I have already mentioned some of our earlier programs, the
x-ray exposure program where we initially evaluate the gonad
dose. We are now in the process of evaluating bone marrow dose.
In addition, we have a system of monitoring where the maj-
ority of the states are now employing the system developed for
Dr. Morgan. Has the 1970 report officially come out yet?
Dr. Shleien. The 1970 GSD report^^is completed and at the
printer. The report on bone marrow doses^/ is in the process of
Dr. Morgan. Dr. Ellett, do you wish to comment on the ade-
quacy of this program?
Dr. Ellett. I believe I did previously.
Dr. Morgan. You have already covered that pretty well. Dr.
Mattson, did you want to make any other comments on the adequacy?
Dr. Mattson. The people from BRH and EPA mentioned a long
list of special studies concerning monitoring. There was some-
thing I left out in response to this question this morning. I
indicated this morning that for particular facilities each li-
censee is required to carryout a rather extensive monitoring pro-
gram for the plant, i.e., effluents from the plant and environ-
mental levels outside the plant.
In addition to that, there are specific studies of a generic
nature which are done by the Nuclear Regulatory Commission. I
have one under my wing at the moment on uranium ore dust in mills
which is a modest study, about $50,000 a year, I think.
I was not prepared today to list all such studies of that
kind that are carried on by NRC from time to time. As particular
questions are raised, or particular issues come into focus, there
are a number of such studies done by our confirmatory research
people or by our inspection and enforcement people or by the stan-
dards development people that I represent.
Dr. Morgan. Thank you. Dr. Sternglass?
Dr. Sternglass. I would just like to take a couple of mo-
ments to point out with regard to the question of adequacy of
monitoring that I was shocked, and I believe you were too, by the
evidence that emerged at the Shippingport hearings that everyone
agreed that the knowledge of just exactly what came out was not
The monitoring was, to say the least, extremely poorly done,
and in some cases there were contradictions between reports of
operators who claimed that gases were allowed to leak out without
being adequately reported.
There were claims that the plant had zero release. At the
same time, other people found a sizable quantity of strontium 90
around the plant and in the fish and in the milk around there,
and this raised the whole question of the adequacy of the monitor-
ing of our nuclear facilities.
I believe that this is a very serious matter in the sense
that people are talking about hundreds and hundreds of these
plants with much closer distances to population centers and areas
where milk, cheese and other food is produced and sent all over
If the monitoring is not improved, I think that we are in
very serious trouble.
Dr. Morgan. Thank you. Mr. Goodman?
Mr. Goodman. I think the overall test is really what hap-
pens to the human beings that are involved.
For some period of time, over a twenty-year period I have
made a study of accidents in the atomic industry, the releases of
radiation exposure. I have offered in recent years on a number
of occasions a list of 500 individuals who were exposed or sub-
ject to radiation. I believe that there ought to be an epidemio-
logical study of the health records of these 500 individuals.
I do not know of any comparable study that has been made on
an overall basis. The workers who work in the industry who have
been exposed ought to be the subject of an adequate medical stu-
dy and I have the names here. I entitled this list simply, "In-
If any of you want a copy, I would be glad to supply it.
Dr. Morgan. Would you furnish one for the record?
Mr. Goodman. I shall.
Dr. Morgan. Thank you.
From my own experience working in national laboratories, I
am under the impression that the monitoring and the care for the
health and safety of the employees in the neighborhood is what I
would term adequate. However, I believe that there have been
some areas under the judisdiction of the Atomic Energy Commission
and perhaps now, NRC, that miss the mark of meeting the standard
that I would say is even minimum.
I am thinking at the moment of the hearings last week, for
example, on the Kerr-McGee Cimarron, Oklahoma plant. I feel very
strongly that they broke all the rules of radiation safety. I
feel the same way about the West Valley Plant, chemical repro-
cessing plant in upper New York. I feel that even some of the
nuclear power plants have not had something that would approach
an ideal health-physics organization where you have personnel of
sufficient qualifications in charge of the safety of personnel.
I would be quick to say, however, that I think that the AEC
and the NRC and ERDA compared to some other industries have done
a remarkable job in keeping track of radiation risks. I only
wish that the fossil fueled power plants industry would do a
little bit as good with reference to the oxides of sulfur and
nitrogen, hydrocarbons and other insults in the environment.
I certainly argue, however, that there are some areas under
the jurisdiction of NRC that can improve.
Dr. Mattson. Dr. Morgan, may I respond to that?
Dr. Morgan. Yes, Dr. Mattson.
Dr. Mattson. I would like to say quickly, that the past re-
cord of monitoring facilities and specifying what environmental
data should be taken, what absolute data should be taken, or how
absolute exposures are monitored and tracked has shown evidence
of weaknesses in the system.
I would like to call your attention to some recent changes
in that regard, both in our regulations and in our regulatory
guides, that speak to these problem areas and ask perhaps that
you personally, at least, would reconsider some of those views
in light of this very recent information.
Dr. Morgan. I am not sure what you have in mind. The plant
I refer to in Oklahoma is not in operation, but it seems that it
took the NRC a long time for it not to be in operation.
Dr. Mattson. I was referring, sir, to the more generic
guidance on monitoring. I was not referring to the Kerr-McGee
facility. I am sorry if I misspoke.
Dr. Morgan. I see, I intended to compliment you when I in-
dicated that in terms of radiation risks we have done a good job,
if we make our comparison to the chemical industry and other haz-
ards in the environment. I would, since you request me to do so,
mention also that when Drs. Gofman and Tamplin, some years back,
suggested the lowering of permissable levels of radiation expo-
sure by an order of magnitude, you went them one better and low-
ered them even more, in fact you lowered them by two orders of
magnitude. I certainly compliment you and your predecessor, the
Atomic Energy Commission that subscribes, not to some fixed level,
but to exposures as low as practicable (ALAP) and as low as rea-
sonably achievable (ALARA), but I think that we can still point
to some operations that you should ride herd on more to improve
your record and your image in the public eye.
Dr. Bross. I believe that the public very often are given
reassuring statements on monitoring. If the statements are true,
they can be taken in a broad sense or a narrow sense.
The statements on monitoring can be confined to the quality
of physics involved in the monitoring process. However, if the
monitoring is doing any good, it should be affecting death rates
and doing something to protect the public.
A monitoring system that may look good on paper may not, in
fact, be worthwhile in practice.
Every time you look at details on monitoring, you get a
shock. In the effort I mentioned about mammography, there is
an effort to take a look at what actually is being delivered to
women who are getting mammography. It ranges all the way from
79-767 O - 76 - 7
300 rrillirems to d hundred times that.
It is a staggering range. This is, in actual practice, a
monitoring system that might be considered adequate in terms of
its paper performance and structure and so forth, is one thing.
But a monitoring system that is doing its job has to work in the
field, and protect the field.
This is what I think the real issue is here.
Dr. Morgan. Dr. Caldicott?
Dr. Caldicott. How can we insure that monitoring will be
sufficient when, as I mentioned, by the year 2020 there would be
100,000 shipments of plutonium on the highways of this country
and if there are accidents, who is going to be around to monitor?
What happens to the people who are exposed, where will the
plutonium be dispersed, in the wind and so on? And what will
happen to people exposed to this released plutonium over thou-
snads of years, number one.
Number two, I have here the statement by Hubbard, Briden-
baugh, and Minor, GE engineers who resigned recently from the
nuclear industry in California, they state, some of the design
defects and deficiencies alone create safety hazards. This is
within nuclear power plants throughout the United States.
"For example, the possibility of failure of the Mark I sup-
pression containments. But the one most important point, and
the point that we want to emphasize to this committee, is the
cumulative effect of all design defects and deficiencies in the
design, construction and operation of nuclear power plants makes
the nuclear power plant accident, in our opinion, a certain
The only question is when and where. These men were top
people in the industry, for many years. I wonder what differ-
ence monitoring will make then.
Dr. Morgan. Dr. Mattson?
Dr. Mattson. Mr. Chairman, I would just note that Dr.
Caldicott is referring to the testimony of the three persons
which was the subject of congressional hearings that were just
concluded recently by the Joint Committee on Atomic Energy. I
do not recall the chairman of the committee's precise words in
summarizing those hearings but they were something to the ef-
fect that he had heard the story from one side and he had heard
it from the regulatory side. He said that he personally was con-
vinced that the regulatory system was working properly.
This is not in debate today. The three people from GE had
nothing to say concerning this dialogue today on low-level radi-
ation. We are talking about the narrow subject of monitoring as
it applies to low-level radiation.
If we get too far afield and start talking about accidents
and what we do in low probability events of a high potential con-
sequence, we will have to go back and revise everything that every-
body said today. We intentionally restricted our earlier remarks
to normal operation, routine things that hapoened with low level
I think we ought to stick to the subject.
!_/ Bureau of Radiological Heath. Food and Drug Administration.
Population Exposures to X-Rays: United States, 1970. Washing-
ton, D.C. Govt. Print. Off. Nov. 1973. (FDA-73-8047) .
y Modan, B. et al . Radiation-Induced Head and Neck Tumours.
Lancet, v. 50. n. 7852. Feb. 1974: 111-11^.
y Lassiter. Laboratory Management Participation in Long Term
Investigation of Man in Occupational Monitoring for Genetic
Hazards Workshop. Annals of the New York Academy of Sciences.
V. 269. March 1975: 43-45.
4^/ Hunt, V.R. Occupational Health Problems of Pregnant Women.
A Report and Recommendations for the Office of the Secretary
of the Department of Health, Education and Welfare. Washing-
ton, D.C. Govt. Print. Off. April 30, 1975. (FA-5304-75) .
y Bureau of Radiological Health. Food and Drug Administration.
Gonad Doses and Genetically Significant Dose from Diagnostic
Radiology. United States. 1964-1970. Washington, D.C.
Govt. Print. Off. April 1976. (DHEW-FDA-76-8034) .
y Shleien, D.Tucker, T.T. and D.W. Johnson. Mean Active Bone
Marrow Dose to the Adult Population of the United States
from Diagnostic Radiology. Bureau of Radiological Health,
(in progress) .
Current Radiation Protection Standards.
Responsibility and Scientific Casis
Dr. Morgan. I believe we had better go on to question 6. Let
me state the question, and I will take a crack at one of the ans-
Who must set the current radiation protection standards for
public and occupational groups and what data are these standards
First of all, I would like to indicate that for many decades
the National Council on Radiation Protection and Measurements
(NCRP) and the International Commission on Radiological Protection
(ICRP) have set what sometimes are referred to as standards for
protection from ionizing radiation through their numerous publi-
cations, but these, as has been indicated, are recommendations. I
underline the word "recommendations."
Although these are not laws or official regulations or codes
of practice, they in fact serve in many instances the function of
regulations and codes of practice. In many cases, for example,
the regulations that exist, the codes of practice are based speci-
fically on these recommendations.
The first official guides at the Federal level in the United
States, to my knowledge, were set by the Federal Radiation Coun-
cil whose functions have now been taken over by the Environmental
Protection Agency. There are many government agencies that have
responsibility at the present time for setting radiation guides,
standards, codes of practice, regulations. I might mention among
others the former Atomic Energy Commission, now the NRC, the En-
vironmental Protection Agency, the Bureau of Radiological Health,
the Public Health Service, HEW, FDA, DOT (Department of Transpor-
tation) , et cetera.
And of course, each branch of the military has its own regu-
lations and the states and a number of local governments have
regulations to control and assure radiation protection and to
And, addressing the second part of the question, by far the
principal source of excessive and unnecessary population exposure
is, in my opinion, medical and dental x-rays. With proper educa-
tion and training, motivation, and certification, and with the
use of improved equipment, I iDelieve that this exposure could be
reduced to less than 10 percent of its present level.
Even a 2 percent reduction in medical exposure would reduce
population exposure more than could be brought about by completely
eliminating the nuclear industry to the end of this century. The
present radiation protection standards wherever possible are based
on human experience -- the cause and effects of excessive exposure,
most of which comes from excessive medical exposure.
However, in many cases, essential data are missing. In such
cases, one must rely on animal studies. The most important human
data on which some of the present radiation protection standards
depend are, for example, the human exposure history with radium
that we have discussed and exposures of radiologists and other
members of the medical professions to x-rays, studies of survivors
of Hiroshima and Nagasaki atomic bombings, studies of medical pa-
tients undergoing radiation therapy, and the studies of Alice
Stewart and many others showing a large increase in incidence of
leukemia, central nervous system tumors, etc. as a consequence of
the use of diagnostic x-rays on pregnant women.
I think again I might have encouraged some of you to respond
to this question.
Dr. Ellett. I think I probably see the question somewhat
narrower than you do. As you pointed out, the NCRP in 1958 made
recommendations for radiation standards. In 1960, the FRC put out
guides that essentially affirmed NCRP recommendations. They were
also confirmed by ICRP in 1959.
If we have to say what data this is based on, we have to look
at what data was available in 1959, not what data is available to-
day. Recommendations, not standards particularly, have been re-
viewed since that time. The current situation is perhaps somewhat
different than it was in 1959.
Certainly the occupational standard for radium was based on
the industrial experience with radium workers and that is when
there was a body of data available. As stated in the IRCP reports,
nobody knew in 1959 if 5 rem per year was equivalent to the radium
limits or not. I do not think that that sort of data became avail-
able until the publication, really of the BEIR Report. They did
have an inkling in 1959 that there was increased leukemia, perhaps
from Hiroshima and Nagasaki data, although that was not at all
If you go back to 1958 and 1959 when the recommendations were
lowered to 0^ rem per year total for individuals in the general
population, the main concern was genetic effects. People really
started to believe that there was not a threshold dose, that there
was harm as far as genetic effects were concerned. Almost no men-
tion of cancer is made in the ICRP/NRCP study, but rather recog-
nition that if you are going to expose large populations, you are
going to have genetic effects and these effects are going to be
with you, regardless of dose.
As to the danger of cancer occurring in the general public,
I do not think there was much concern expressed in the recommen-
dations. As near as I can find out, the philosophy was that doses
should be ten times less for people who were not occupational ly
exposed. As the ICRP points out, we assume the occupational stan-
dards for radiation place radiation workers under risks comparable
to other occupational hazards in industry. There was a balancing
of risk against risk, if you will, so that there would not be some-
thing exceptional in the health effects observed in the radiation
workers as long as their exposures were under NRCP/ICRP recommen-
When it came to the general population, I don't know whether
it is fair to balance an occupational risk situation as against
people who are not profiting by their employment and getting a
radiation dose. The way NRCP and FRC have handled this is to say the
risk should be somewhat less, that is a factor of 10 less.
I don't know but that if we had a number system based on 20
instead of 10 it would be a factor of 20 less, rather than 10. I
have never seen a real rationale for what dose we allow for the
Dr. Morgan. I would take issue with some of the things you
said. I was a member of NRCP and IRCP through all of these years
and I was Chairman from the beginning of the Committee that pre-
pared the internal dose report that you referred to. We did have
access to some of the reports of the Hiroshima and Nagasaki survi-
vors. We had access to some early data on the effects of exposure
to the fetus, and we were particularly alerted to the human his-
tory on radium exposures; so much so that our standard was the 0.1
microcurie of radium in the body that corresponds to 30 rem per
year. This was used in calculating the permissible dose for all
the bone-seeking radionuclides.
We did look very carefully at the history of the exposures of
the radiologist. That basically is where our present figure of 15
rem per year for most body organs came from. The British felt
that the average exposure of early radiologists was of this order
and that led us to have the two reference standards, namely 30 rem
per year from radium 226 and 15 rem per year average exposure of
the radiologist during the preceeding decades.
So we did have a great deal of this data for our evaluation.
I remember Dr. Muller, the geneticist, and I worked closely to-
gether through these decades in preparing radiation exposure re-
commendations. We had many arguments on whether the genetic risks
or the somatic risks set the boundary conditions for radiation ex-
posure levels. And so these discussions went on for a decade at
least before the ICRP reports themselves came out in print.
Dr. Bond. I should like to extend the remarks that you and
Dr. Ellett made. I do not speak for the NCRP or the ICRP. With
respect to the data, radiation standards have been based, histori-
cally on findings of scientific committees of the NCRP and ICRP.
These councils attempted to call upon the best talent available
to help evaluate scientific data.
In this country the NCRP has done this; in Britain, the MRC
has done the same thing. At the time that fall-out was an issue,
the British report was prepared and the so-called BEAR (Biological
Effects of Atomic Radiations) Committee was preoared. This was in
the middle 1950's.
As far as I know, as alluded to, it was the report of the
genetic effects part of the BEAR Committee that had a great deal
to do with standard setting at that time (mid 50 's) and led
fairly directly to the recommendation of the NCRP standard for
the general public. In practice, this has been used very widely
as the standard. It was the Genetics group of the BEAR Committee
that stated, after a very careful review of the genetic effects
data, the best available data at the time, that in their view, in
order to get the jobs done 10 rems over 30 years might have to be
"allowed" as an upper limit. That included medical x-ray expo-
sures. This evolved into 5 rem over 30 years or 0.17 rem per year
for the general public for all man-made exposure except medical.
This was adopted as a recommendation for the general public
and I would like to say that this committee stated very clearly
what Karl Morgan also stated here -- that any numbers adopted as
standards, are to be taken as upper limits, and that in fact the
exposure should be kept to the lowest degree practicable.
Obviously, these committees used the best data available at
the time they met. Later committees have been appointed and the
information has been updated. The main point is that the groups
having to do with radiation standards have attempted to avail
themselves of the best data and talent available.
Dr. Morgan. Dr. Bertell.
Dr. Bertell, If that recommendation was that they be exposed
to no more than 10 rem in a generation, then there was another
assumption implied, namely that 5 rem would come from medical,
and therefore you could distribute the other 5 over industry, is
Dr. Bond. Essentially correct, but not precisely. The pre-
cise figure, I believe, was three or four, and the rest for atomic
energy. That evolved into recommendations for other groups that
there should be allowed an upper limit of 5 rem for the public,
over 30 years, from all sources other than medical exposure.
Dr. Bertell. There was an assumption there that we were getr
ting about 5 anyway from medical sources, I think also in the
beginning. Dr. Morgan, you said something about 73 millirads per
year assumed medical exposure?
Dr. Morgan. This figure is a result of the Bureau of Radio-
logical Health studies. In 1969, their data were evaluated and
they came forward with the number 73 rem per year to total body
of the average person in the U.S. from medical exposure.
Dr. Bertell. I would just like to give you the figures from
the Tri-state survey on what people actually were getting on medi-
cal x-ray. This is over a ten-year, approximately ten-year period
Dr. Morgan. Excuse me, are these total body figures?
Dr. Bertell. Total body for medical x-ray, and that includes
dental. The male controls averaged 10.37 rads in a ten-year per-
iod. The male cases 13.47 rads. Female controls, 11.7 rads and
female cases 13.14 rads.
If we are talking about 10 rads over a 30-year period, we are
already over this limit when we just talk about medical x-rays. In
the DHEW Report of 1970 on the exposure to medical x-rays in the
United States, the estimate I could come up with, as an average
per person, was 642 millirem per year external from medical x-rays
not including dental .
If you project that over a 30-year period, you are already up
to 19.26. What we are saying here, even if you cut medical x-rays
in half and take dental out, you are about at that 10 rem level
over that 30-year period.
Dr. Morgan. Thank you. Dr. Schleien?
Dr. Shleien. We are talking doses to different organs. The
standards are based on population doses, particularly genetic doses,
over a 30-year period, and the latest reports on the genetically
significant dose per capita, average significant dose, is 20 milli-
rems in 1970.
The 72 millirem figure was a mid-abdominal dose, really not
a whole body exposure dose. The values you are quoting appear to
be skin exposure so consequently we are talking about three or four
different organ doses.
I think the genetically significant dose is the dose referred
to in the publication that Dr. Bond quoted in which 20 millirems
Dr. Bertell. What about the 170 mrem? Is that not whole body
Dr. Shleien. That excludes medical radiation.
Dr. Bertell. It is whole body. Is it not external? Is it
Dr. Shleien. Whole body or bone marrow dose per year. It
is the absorbed dose, not exposure. Furthermore, the limits may
be numerically equal but the doses to the organs may vary. This is
whole body or gonadal. The limit works out to be the same. A 5
rem gonadal dose over 30 years is 170 rems. A 0.5 rem whole body
dose to an individual works out to be about 170 mrems per year for
a suitable sample of the population.
Dr. Bertell. That is a split-up of the 5 rem. It is not
spread over --
Dr. Shleien. Exclusive of medical radiation.
Dr. Bertell. I am trying to figure out why part of that, the
5 rem you are telling me is gonadal if it has to do with medical
x-ray, the other 5 rem is total body dose.
Dr. Shleien. I was not saying that. I was saying that the
present radiation standard excludes medical radiation. That is
the first point.
The second point that I was making is that the studies on
which the standards were based included, when the calculations
were made to evaluate the total dose, medical radiation.
Finally the last number we have on the genetically signifi-
cant dose is 20 millirem per year. The doses that you were quot-
ing appear to be for individual procedures, and they appear to be
skin exposures, not specific organ doses.
Dr. Morgan. Dr. Bross?
Dr. Bross. I originally had not intended to comment on this.
I think maybe some of the audience is confused by the discussion
here. I thought I would summarize it in my own way, by asking:
What does this all indicate about the way standards are set?
First of all, in case you did not get the message, the stan-
dards are set on data that is ten or fifteen years out of date. In
the second place, if you failed to get the message, the standards
are set using methodologies such as linear extrapolation which are
even longer out of date.
The way in which the data arises is of interest, I think, for
the group. How did we get this data that has been cited? The
reason that we have data, for instance, on what happens to women
when they get 200 rads delivered to their breast to deal with post-
partem problems is because the radiologist thinks it is perfectly
safe to do so. The radiologists give it, and ten or fifteen years
later 15 percent of these women get breast cancer before they are
50, then we know that there is a hazard.
What I am talking about now is the general process, the pro-
cess of setting standards. We set standards by obsolete methods.
By the time we take any action on older hazards they have
been replaced by new ones. This time lag results in our constant-
ly, as far as our present population, being exposed to hazardous
Dr. Morgan. Dr. Mattson?
Dr. Mattson. Dr. Bross, I believe, gave his view before, but
I think it contains a small confusion over the recommendations,
standards and Federal regulations issue.
It is true that the first recommendations on accpetable levels
of radiation came out some years ago. It is also true that those
recommendations have been reviewed by the recommending bodies many
times since then on specific issues and general issues. There are
many committees that continue to meet and consider these issues.
They reaffirm their recommendations from time to time.
Federal regulations concerning radioactivity, that derive in
some large measure from these recommendations, change yearly.
Our part 20 radiation standards, I would guess have changed
on the order of five times a year, every year, since I have been
faciliar with them. They change on small things, like signs
used to control radioactivity or procedures used to work around
As to the application of radiation protection principles to
specific facilities, it is just not true that these things are
fifteen years old and have not changed since. That is not the
case; they are kept current with the evolving state of knowledge.
Dr. Bross. I would like to ask: Specifically we have been
talking about 5 rem standards, for instance. How long has that
been in effect? on
Dr. Mattson. That has been in effect a long time. It has
been restudied many times.
I can point to the ongoing EPA study of the 5 rem standard,
if that is the one you refer to.
Dr. Bross. What I would say is the study simply reaffirms
the previous standard without bringing in the new evidence, which
is exactly what has repeatedly happened, this is not updating it.
Dr. Morgan. Dr. Sternglass?
Dr. Sternglass. I want to say something exactly to this
Much of the information that needs to be examined has simply
only come about in the last three or four years. The last time
that the BEIR Committee had a chance to examine this whole ques-
tion at the request of the EPA was in 1970-71, and a lot of the
data of Dr. Sanders at the low dose dates, the Rochester study
on the dogs exposed to natural uranium, and the recent data from
Dr. Petkau's studies on membranes of mice, altogether a tremen-
dous amount of data, has simply only come during the last few
years and it needs to be fed into the system. It looks to me as
if when this is done, we will have to end up with some signifi-
cant lowering of our permissible dose from environmental sources.
Dr. Morgan. Dr. Richmond?
Dr. Richmond. If you are interested in reading more recent
related information, I might recommend NCRP-43, which is an up-
date of the risk estimates.!/
Dr. Sternglass. It did not take these particular studies of
membrane damage into account.
Dr. Richmond. Let me comment.
The National Council on Radiation Protection and Measurement
is an organization of 70 individuals representing all sorts of
disciplines, the medical profession, I think legal, but many. We
have to assume that somebody, some group acts responsibly. They
have a charter. There are similar international organizations.
I do not know what more one can do. All you can do is say,
well, they are not apparently using the information that an indi-
vidual believes is very pertinent to the question.
Dr. Sternglass. That is right. That is why, at the recent
EPA hearings, I suggested that by law the EPA must take this kind
of new information into account when there is no legal restraint
on the NCRP or the ICRP or for anyone to take into account any
particular data at all.
But fortunately, under the National Environmental Protection
Act, the EPA must, by law, take into account all the latest data
and not select what it chooses to do in order to maintain an in-
dustry in operation.
Dr. Richmond. Your point is a good one. Let me caution
against one thing.
I think the words are "any reasonable" something or other.
My point is that, I do not mean this in a derogatory sense at all,
but a constructive sense, there are so many issues that beset us.
How can we ever begin to act in depth on every one?
We have to assume that there are bodies of experts who, in
conjunction with regulatory agencies and public perceptions and
public input, will make the right decisions. If you do not buy
that, you do nto buy the way the system operates.
Dr. Sternglass. I certainly buy the way the system operates,
but the system will operate in the future under the inspection of
the public in far greater detail than it did in the past. All
these things were done in secret without anybody having access to
any of the material on the basis of which the decisions were made.
Dr. Morgan. Dr. Bond?
Dr. Bond. Let me say again, that at the time the BEIR Com-
mittee Report was organizing its activities, it let it be known
far and wide that this activity was going on, and data from any
individual or group was solicitied. All of the data submitted
were considered, and considered in detail -- including the data
submitted by Dr. Sternglass. All of the data were taken into
consideration, to the degree that the committee thought they
should be, in coming out with recommendations and conclusions.
Dr. Morgan. Dr. Caldicott?
Dr. Caldicott. If you thought plutonium actually does go to
the gonads and there is data to show that it does, how do the re-
gulating commissions in the government, therefore support an in-
dustry which produces plutonium which will inevitably, at some
stage or other, contaminate the gonads of individuals in this soc-
iety and the world?
We are not just talking about America; we are talking about
proliferation of nuclear power plants throughout the world.
Dr. Morgan. I think we had better go on to question 7. I
do not think we can answer completely question 6 at this meeting.
If we had a week to address it, I think we could do better.
Dr. Ellett. I would like to say something in answer to a
rather provocative statement that was just made. I think in this
country. Congress has decided on what we are going to do about
radiation. It is not the responsibility of the regulatory com-
missions, as Roger Mattson pointed out, to turn the nuclear indus-
try on or off.
The plutonium decisions are being made pretty much by the
money that is appropriated by Congress for the breeder reactor and
I think it is misdirected energy, really to try to examine these
programs in as narrow a context as what the health effects are.
There are very big problems that have both costs and benefits
associated with them. Just to hang on one point might be a
rather narrow perspective.
Mr. Goodman. The problem is that the agencies do not total-
ly inform the Congress. I refer particularly to the suppressed,
revised WASH 740 Report that had, in its initial draft, a much
different conclusion than the agency has recently purchased from
Therefore, it is impossible to rely upon the conclusions
made by the Congress if the agencies are going to misinform the
Dr. Morgan. Dr. Mattson?
Dr. Mattson. The WASH 740 Report referred to is ten years
old. It was done by an agency that does not exist anymore.
I think we ought to get back to low-level radiation.
Mr. Goodman. They were discussing low-level radiation, but
the report, not being an acceptable version, was suppressed.
1_/ U.S. National Council on Radiation Protection and Measurements.
Review of the current state of radiation protection philosophy.
Washington, D.C. Jan. 15, 1975. 50 p. (NCRP Report No. 43).
Health Effects of Radiation
Is the Data Base Adequate for the Determination of Standards?
What Research is Needed?
Dr. Morgan. I think we had better go on to question 7. Let
me read it and make a quick response. Is the data base on which
these standards are based adequate to determine health effects?
What areas of data collection and research need more attention
Ironically, we probably know more about the harmful effects
of ionizing radiation than about any other environmental agent.
But the more we know, the more we need to know, because although
the genetic risks of low-level exposure may be somewhat less than
we considered them to be two decades ago, the somatic risks and
in particular the risk of radiation-induced cancer of almost every
type are more to an order of magnitude greater than we considered
them to be sometime back.
We very much need to have more research on low-level exposure
to Plutonium and other transuranic elements. We need chronic ex-
posure data on large animals and man, and microdosimetry on bone,
lung and liver and of the effects over several decades of exposure
We need more information on the environmental behavior of
these elements and the migration in man's ecosystem. We very much
need more information on the carcinogenicity of concurrent insults
to man, for example, diabetes, respiratory diseases, smoking, ex-
posure to SOx, NO^, hydrocarbons, food additives, drugs, radiation
Let us have some responses to this question. Dr. Sternglass?
Dr. Sternglass. I fully agree with the Chairman. I feel
these are precisely the areas that now need attention, especially
since we have learned that synergistic effects of the kind you
mentioned are extremely important.
We know, for instance, in the case of the uranium miners, if
they first inhale pure radon gas and do not smoke, their rate of
lung cancer increase is much less perhaps by ten or twenty times
than if they also smoke, and it is precisely these kinds of in-
vestigations at low dose rates, low dose effects by all types of
ionizing radiation that we must find ways to encourage.
If also means not only laboratory experiments on animals of
the kind that Dr. Sanders and J.B. Little at Harvard are now do-
ing in connection with the possibility that plutonium is an impor-
tant factor in the health effects of smoking cigarettes, but it is
necessary now to do the long-neglected studies of large popula-
tions exposed to fall-out throughout the world, because these pop-
ulations must now be examined with the most advanced statistical
techniques, the best statistical techniques available.
Since we have no other human exposure that is at this low
level and in low dose-rate, the medical doses do not give us the
same kinds of evidence; therefore, we need to undertake and fund
studies of populations in different parts of the world exposed to
different amounts of fall-out in time and in space. We need to
do the same thing with populations living around nuclear facili^
ties that have now been in operation for more than thirty years.
We must come to grips with what in some cases are, unfortunately,
likely to be some very disturbing discoveries.
But unless we ere willing to face the facts and do the stud-
ies on fall-out, we are committing our society to a major source
of energy that could produce an enormous increase in our somatic
and genetic effects in the future.
Dr. Morgan. Dr. Mattson, do you care to comment on this
Dr. Mattson. I think I said earlier today that we are stay-
ing in close cognizance of the ERDA research program on the effects
of radiation. I believe that program has been on the order of
$30 million to $40 million to $50 million, it fluctuates somewhat
over time, in this general area for many years. I believe it is
on the order of $45 million, as I understand it, in fiscal '76.
That is all in the area of radiation hazards.
We think that research program is aimed at the kinds of things
that you spoke of. I think we generally agree with your broad
categories of important areas of research.
As far as NRC is concerned, we have no research at the moment
in health effects, per se. That is, we have no direct research to
determine what happens as a result of radiation exposure of humans.
We do have in a broader context, though, quite a lot of effort
being spent to study the movement of radionuclides in the environ-
ment or in man. We also develop calculations or analysis methods
for these kinds of things, including the controls of radionuclides
in a facility such as the control technology for protecting workers
and control technology for radioactive effluents.
We also have modest efforts in research of monitoring tech-
niques because the regulatory actions we have taken in recent years
have pushed the state of the art a little bit on monitoring. We
have had to do some confirmatory research to prove we could really
monitor at the low levels we were requiring.
Beyond that, I would make the general statement that the fed-
eral research program, as we understand it, is generally on the
right track and it is likely to yield answers to the questions that
you spoke of in introducing this topic.
Dr. Morgan. Dr. Shleien?
Dr. Shleien. I would like to take the opportunity to mention
some of the projects relative to bioeffects that the Bureau and EPA
is presently engaged in.
I think they relate generally to the discussion. One is the
F-2 effects from x-rays on the human female fetus, specifically x-
rays on pregnant women.
The second is a study to determine the risk of thyroid tumor
development associated with low-dose x-ray radiation. The Colorado
State Univeristy study, which is a longterm study on beagle dogs,
a very large study, on the ionizing effects of radiation when de-
livered at various periods in development of the beagle.
There is a National Academy of Sciences contract on an evalu-
ation of the extent of the use of medical radiation in benign dis-
ease. There are the studies undertaken by the Bureau itself in
terms of relative carcinogenicity of Iodine 131 and external radi-
Dr. Morgan. Mr. Barnett?
Mr. Barnett. With respect to some of the information we still
need in the medical radiation area, we would like to know more
about the efficacy and in some instances the biological effects of
potential x-ray substitutes, such as ultrasound. And with respect
to some of the more traditionally conducted x-ray procedures we
would like some information on the efficacy of these examinations
when carried out in certain clinical circumstances, so that we can
provide physicians with more concrete advice as when to order or
not order a given x-ray procedure.
Dr. Morgan. Dr. Bertell?
Dr. Bertell. If we are talking about an adequate monitoring
system, it is essential to talk about adequate monitoring of peo-
ple. I would say that one of the sources of much of the disagree-
ment on this nuclear question comes from inadequacy of the vital
statistics to give us the information which we need about environ-
This situation will exist until we are willing to redesign
our vital statistics in such a way that they give us the informa-
tion we need. It is not an esoteric question, it is something we
know how to do and it could be done.
Until we have a national data bank which gives us information
on people who are exposed to radiation in their occupations, until
this is no longer a split between GE, Westinghouse, Government fac-
ilities, and so forth, until there is a standardized way to collect
information on workers, until we collect it on the offspring of
workers and have a national way to process this data, until we up-
date the questions on vital statistics, our monitoring is inade-
Dr. Morgan. Thank you. Dr. Bond?
Dr. Bond. I would just like to make a comment without a judg-
ment that monitoring of any environmental agent, any period, re-
quires resources in terms of money and manpower. No one is against
monitoring to any degreee commensurate with need and with resources,
but I would say that there are many agents in the environment, many
agents that are toxic.
To monitor these things requires money and resources. In the
overall question of degree of monitoring, this risk-balance equa-
tion has to be addressed. We cannot look at radiation in iso-
lation in this respect.
Dr. Morgan. Dr. Bertell?
Dr. Bertell. I agree totally that it has to address every
environmental question, I would suggest that if we need money
we use the money now being used to continue what I consider fruit-
less research on the breeder reactor.
Dr. Morgan. Mr. Jablon?
Mr. Jablon. I would like, if I may, to tie these two remarks
together. The speakers have come to a subject that is near and
dear to my heart. The fact of the matter is that the vital statis-
tics system in this country was built, I presume, for certain pur-
poses, but it is a remarkably ineffective device for the research
In Japan, we have been able to prosecute a long-term follow-
up study on 100,000 persons, survivors of the bomb, and this was
possible only because the study could be based on the Japanese vi-
tal statistics reporting system. It would not have been possible
to mount such a study in this country.
Not only for the sake of monitoring persons who had exposures
to radiation, but as has been said, for other occupational hazards,
for studies of health of all sorts, we have got somehow to struc-
ture our vital statistics reporting system so that the kinds of
studies that are needed can be done at a reasonable cost. For ten
years, at least, there has been agitation in this country for some-
thing called the National Death Index, so that if you are trying
to follow a thousand people you would be able, in a simple way, to
find who was alive and who was dead and what the dead person died
We have made absolutely no progress at this time. There are
a host of other things that could be done, but if we could get our
vital statistics reporting system straightened out and amend the
privacy act so that we can use the files, under suitable safe-
guards, we can begin to make progress in some of these areas.
Dr. Morgan. Thank you. Dr. Ellett?
Dr. Ellett. First, as to whether or not the data base for
radiation standards is adequate or not, let me say that the BEIR
Report is a very adequate study. Perhaps it underestimates the
risk in some cases and overestimates in others but I think it is
a very good study, probably the best thing presently available
on which to base public policy and decisions on radiation
Frankly, my worry is that people will tinker inadvisably
with the BEIR Report to make risks greater or less. EPA is
having discussion with the Academy now about having the BEIR
Report updated. There are questions that have come up, but I
do not believe that BEIR Report numbers are going to change
radically in the near future.
In its consideration of radiation protection standards,
the nation would be poorly advised to wait for more data. I
think we have a good data base, certainly more than we have for
any other pollutants.
The second part of the question referred to what areas of
data collection and research need more attention and funding.
I think that the Federal establishment is particularly weak in
doing epidemiological studies on radiation effects. I think
we are weak in knowing what happens to children who have been
exposed, in childhood - as they grow older, and also what is
the ultimate fate of people who have been irradiated in utero.
Nobody has been able to do a study to trace what happens to
in utero exposed people when they reach the age of 40 - 50.
This does not mean I accept the "new" information on
health effects presented this morning and this afternoon. Very
little of that information is really new and I disagree with
almost all of the assertions made this morning concerning new
and unexpected health effects.
Dr. Morgan. Dr. Martell?
Dr. Martell. I think there is one area in which the present
standards are extremely poorly based, and that is with respect to
the chronic effect of internal alpha emitters in soft tissue. This
is a problem we have averaged away. The NCRP and ICRP have only
talked in terms of average dose and average burden of internal
alpha emitters. It was not observed that there were considerable
differences in the physical and chemical properties of natural and
pollutant radioactivity in soft tissue. Natural alpha radioacti-
vity, radium, and polonium are soluble and uniformly distributed
in the lung and in other soft tissue organs, unless thay have been
converted by human activity into an insoluble particulate form.
In the case of plutonium and other transuranium elements, the ox-
ides are naturally in an insoluble particulate form.
In studying the distribution of insoluble particles in man -
not just plutonium but also insoluble particles that are present in
cigarette smokers - the problem of internal alpha emitters as an
agent of cancer in smokers has been ruled out because the total
activity in the lung was only two or three times the natural alpha
activity in the lung, but, in fact, as tumor sites insoluble alpha
emitters in cigarette smoke are thousands of times higher than the
natural alpha activity. The latter is distributed uniformly in
soluble form. The insoluble particulates are highly localized in
the bronchi .
79-767 O - 76 - 8
We are finding that here the residence time is of the order
of six months. We have unpublished data to suggest that at other
sites in the lung, it is much longer -- on the order of two years
On the basis of a two-mutation hypothesis: on the basis of
local alpha doses which are thousands and tens of thousands of
times higher than natural, we have, I think, good basis for sug-
gesting that these insoluble alpha emitters may be a principal
agent, the principal candidate agent of cancer in smokers. And
we are talking about only a fraction of a picocurie at smokers'
tumor sites -- not 16,000 picocuries (the MPLB for plutonium).
This is an area where we seem to have a discrepancy about the
significance of an organ burden by a factor of 10,000 or more.
The two-mutation hypothesis is consistent with the age dis-
tribution of cancer in the smoker and non-smoker groups. The act-
ivity concentrations at the tumor site reinforce this possibility
in terms of alpha radiation dose consideration. This hypothesis
has been ignored by the NCRP, the ICRP and others responsible for
radiation standards. I suggest that this is a hypothesis that can
be tested and that it is time that we did so. Because if only
fractions of a picocurie in human soft tissue organs can give rise
to a significant, unacceptable tumor risk, why are we talking about
proliferating alpha activity pollution with tons of plutonium and
other alpha emitters.
I suggest that this is one of the very serious questions that
we had better address ourselves to, if there is to be any purpose
to a meeting of this kind at all.
Dr. Morgan. Thank you.
Dr. Richmond. I want to make an observation at this point.
I believe there are some areas that should be reinforced or im-
proved in the general area of health protection and radiation bio-
logy. I think this is true with almost any subject. I guess where
I have my concern, is to look at all the so-called biological in-
sulting agents that man is exposed to in his environment. This in-
cludes many heavy metals, it includes all kinds of interesting or-
ganics, pesticides, the list is huge. In fact, for those of you
who are interested, there were some House Committee hearings held
last year on the cost and health effects of low-level exposure to
pollutants, including radiation.
The point that I am getting to: there are many materials that
get into the lung and do damage; many materials that get into the
gonadal tissue and can cause mutagenic effects. The question is,
how thoroughly can we, as a group, society, study all of these pos-
So I think there is a brighter side to this coin, too, that
we indeed do know and have quite an amount of information for rad-
ioactive material, but there is still a lot to be learned. How-
ever, there has to be a very important national decision made, I
think, in how much of our total resources can be committed.
Let me give one other example. We are all fully aware of the
situation that developed many years ago when the uranium miners
worked deep underground. A fair number of them who smoked and were
exposed to other materials developed lung cancer. However many
> people seem to ignore the fact today that the tax bill for black
lung disease of coal miners is $1 billion a year. That is $1 bil-
My point is, and I think we all have to learn this -- there
is a cost, a biological, environmental cost, for whatever we do
We are only now learning how to quantitate this cost for different
integrating cycles of producing energy. It is a two-sided ques-
tion. I do agree there are areas that need additional work in the
radiation field specifically.
Dr. Morgan. Thank you. Dr. Caldicott?
Dr. Caldicott. Of the most mutagenic agents, we know pluton-
ium is one, and we have just heard evidence about how carcinogenic
it is. In fact, it has been stated that there is no dose low enough
which will not produce lung cancer in dogs. We know and we have
heard that it migrates to the gonads, the testes and the ovaries.
Six percent of all children born now have some sort of congen-
ital defect; 30 percent of the admissions to all pediatric hospi-
tals are related to inherited disease and deformity; 10 percent of
all admissions to adult hospitals are related to inherited disease.
As Plutonium is so mutagenic it most surely will produce mu-
tations within the eggs and the sperm which will be obvious in
future generations if it is deposited in the gonads, if it is in
If we go ahead with the plutonium economy, almost surely we
will become contaminated; we are already from the fall-out. Do we
risk our future generations of children? Is that the risk we are
prepared to take for the benefit of turning on electric lights?
Dr. Morgan. I would like at this time to call on representa-
tives from ERDA. I see Bill Burr here; would you care to respond?
Dr. Burr. Yes, sir.
What I would like to do is discuss briefly the scope and gen-
eral magnitude of the ERDA research programs in this area.
I thought it might be useful to say a little more about some
of the work that is currently under way.
Dr. Mattson has touched on this. He has noted that we have
perhaps $40 million or more in funds allocated for the health ef-
fects area and it is this research about which I would like to
speak. In addition, we fund research in the environmental area,
including the movement of radionuclides through the environment.
We also have work in our physical and technological programs
for better instrumentation and procedures, but I really want to
focus on the health effects studies.
Of that $40 million, approximately $10 to $11 million are for
human health studies. A number of these have been mentioned this
morning, and I want to just touch on them again.
In the epidemiologic area, our largest committment is in sup-
port of the studies in Japan of atomic bomb survivors by the Radi-
ation Effects Research Foundation, formerly the Atomic Bomb Casual
ty Commission. The gentleman on my left, Mr. Jablon, can tell you
more about this project.
We have a major effort in the Transuranium Registry. This
has been touched upon as well. We still have an extensive program
at the Center for Human Radiobiology at the Argonne National Lab-
oratory for the follow-up of radium workers and additional indi-
viduals who were exposed, for other reasons, to radium.
This work has been cited before and has been the benchmark
as far as human data is concerned for bone seeking internal emit-
ters. It continues to be an important area of research.
We have a health and mortality study that does not embrace
all of ERDA's activities but is quite large in its scope. It has
been going on for a number of years. This study of workers ini-
tially involved the workers at Hanford in Richland, Washington
and those at Oak Ridge. It has been extended in recent years to
some other laboratories.
We are adding to our epidemiological efforts in plutonium.
We agree that this is an area that needs to be strengthened.
Rather quickly, the other portion of this $40 million, the
$30 million or so, is devoted to our studies of experimental
systems, and of this, about $10 million is in the internal emit-
Since the question has been raised, I will point out of that
approximately $8 million is devoted to the metabolism of alpha
emitting radionuclides and their effects. Other studies involve
radiation damage in organs and cellular and molecular systems. I
will not go into that research.
The genetic studies in experimental animal systems represent
about $4 million of effort.
In addition to this brief summary we have some descriptive
material that I would like to leave with the committee. Dr. Morgan
Dr. Morgan. Thank you very much. Maybe some of the panel
members have questions they would like to direct to you?
Mr. Myles of the Environmental Study Conference has a state-
ment he would like to make at this time.
Mr. Myles. I would like to add that we asked the National
Cancer Institute what kind of research they are currently doing
on radiation health effects, and we got responses from Dr. Marvin
Schneidermann and Dr, Robert Miller who is the Chief of the Clini-
cal Epidemiological Branch of the National Cancer Institute.
Basically they said that the NCI is doing almost nothing, or
, certainly nothing new in research in radiation health effects.
Dr. Miller added that they have some continuing funds involved
in support for the Radiation Effects Research Foundation, studies
of head circumference among children who were exposed to that atom-
ic bomb in utero, funds to the National Academy of Sciences, Nation-
al Research Council for the study between the relation of pre-natal
diagnostic x-ray exposure anc cancer in childhood and the Clinical
Epidemiological Branch has issued a monthly Childhood Center Epide-
miological Newsletter since 1973.
This suggests, I think, to some people that the National Can-
cer Institute should be doing more in radiation health effects re-
Dr. Morgan. Dr. Bross?
Dr, Bross. I think I should mention that I have been omitted
from that list. That is because our research is on biometric re-
search and cancer epidemiology and general methodology and not
specifically on radiation hazards exclusively. I think that if we
had gone in for funding on that, we would never have gotten the
funding. I think that there is also other work being done by the
NCI. Just for the record, I would read in our Grant Number CA11531,
because these people like to have that mentioned.
Dr. Morgan. Dr. Edsall?
Dr. Edsall. The people that you consulted at the National
Institute of Health, did they give a rationale for the decision
not to have any but a very small program in this area?
Mr. Myles. No, there was not any real attempt, as far as
I could tell, to explain why they did not have more money or re-
search funding involved.
Dr. Edsall. Suppose they probably feel that because work is
probably being done by other agencies in this area that they do
not need to do it, but it does seem to me a very unbalanced kind
of program in the NIH or the National Cancer Institute, that they
have so much going on in the cancer field and almost nothing in
Dr. Morgan. Dr. Archer?
Dr. Archer. I recall two studies that the National Cancer
Institute have done pertinent to this discussion that were pub-
lished fairly recently. One, the mortality study of the people
in Mesa, Colorado, a county in which Grand Junction is located.
They were especially looking for an increase in lung cancer
which they failed to find. They did another study in which they
attempted to do the sort of thing I was talking about earlier
this morning, trying to relate cancer to background radiation.
This was reported two years ago, I think. The results were
negative. They found no effect.
As they indicated this morning, I think they were working
with some incorrect assumptions.
Dr, Morgan. Mr. Jablon?
Mr. Jablon. It is not really my place to spring to the de-
fense of the National Cancer Institute but I should say that in
conversations with the people there, two things have been plain.
It is their feeling that other agencies, especially ERDA, have a
primary interest in radiation effects per se and that there is no
reason for them to go into competition.
Secondly, that they do have an interest in cancer, and if
anybody goes to them with a contract proposal or project which
seems suited to their needs, investigating the epidemiology of
cancer, they have been forthcoming. And in fact, as was mentioned,
they have put fairly substantial funds into what was formerly the
Atomic Bomb Casualty Commission, now the Radiation Effects Re-
search Foundation at a time when, for various reasons, AEC was
finding it difficult to find all the money that was required.
So I think they have been responsive.
Dr. Morgan. Thank you.
The Chairman will declare a five-minute recess.
(A brief recess was taken.)
Dr. Morgan. Dr. Bertell has a comment she would like to make
regarding the previous discussion.
Dr. Bertell. I think that we were talking about the adequacy
of the research and we have already talked about some of the as-
pects, such as the understanding of the biological mechanism.
Again, the way you understand the mechanism affects the way you
look at the data and how you report it.
We have talked about data collection and the inadequacies
there. There is one other big area which has not been mentioned
as yet, and that is the techniques of mathematical analysis of the
data, and I think that that also is another big area which needs
to be updated. I have worked quite a bit to try to update the
handling of this type of data and the measurement of things which
seem very vague, like the aging effect, which are hard to get a
Unless we are willing, also, to update in the methodological
area, I think that the research is inadequate.
Dr. Morgan. Thank you. Dr. Bross?
Dr. Bross, Presumably, since we are speaking about recommen-
dations for congressional groups, that since one point did come
out at the very end, namely funding of research, I would like to
put a policy statement in at this point.
You heard that the National Cancer Institute essentially was
not funding very heavily in this area because it was relying on
other agencies. This can happen when research responsibility is
spread around. What I would like to recommend as a policy is that
^health research be carried out by the agency whose mission is the
'protection of the public health rather th&n by an agency with an-
Health Effects to Occupational and General Populations
Exposed to the Present Federal Standards
Dr. Morgan. I think we had better go on now to the next
question. We are going to have to select the remaining questions
in order to conclude by 5:00 o'clock.
Question 8, I think, has been addressed, perhaps sufficient-
ly: What health effects would result from public and occupational
exposure to the legal limits allowed by Federal standards?
Dr. Mattson, would you like to address this?
Dr. Mattson. If we understand the question correctly, it
has already been addressed by the BEIR Committee. I think the
numbers to answer the question come straight from the BEIR analy-
Perhaps the conclusions were not precisely stated there, but
it is a simple calculation, using the BEIR calculation model.
I recall that the BEIR Committee used a base of 0.1 rem per
year. I do not have the calculation performed for the assumption
of the general population being exposed at the occupational limit.
We have performed a calculation at 500 millirems, assuming that
everybody in the United States was exposed to that level. It is
a really large number.
It ranges from something like 2.2 to 10.8 percent increase
in cancer using that number, depending on whether you use the ab-
solute risk model or the relative risk model of the BEIR Report.
I think to say that the entire population of the United States
would be exposed to 500 millirems from any given source is a bit
We have made another calculation which might be more appro-
pos to a specific source of radiation. That calculation used our
regulatory design objectives for light water reactors effluents
and assumed that everyone in the United States lives within a 62-
mile radius of a two-unit light water reactor station, which is
designed and operated according to our regulation. Within that
62 miles we assumed a distribution of the population typical of
what you might see for facilities operating today.
Using the models for Appendix I to 10 CFR, Part 50, Design
Objectives for the operation of these facilities, we could calcu-
late over a 30-year operating life about five excess deaths --
if that is an acceptable term. In some circles, it is not; per-
haps in this one, it is. Five deaths. That is compared to the
normal incidence of cancer death in the United States in 1974 of
350,000 people per year.
I am sorry -- these are not deaths, it is the total number
of cancers. In summary, the number we have calculated is 5 com-
pared to 10,500,000 from other causes.
I do not know if it was the intent of the question to get at
these numbers. As you can see, it is kind of a numbers game. You
can start out with the BEIR Committee numbers which are based on
the linear hypothesis and use the upper limits standards. You can
^ then go within those standards and say that not everyone in the
'population receives the upper limit, so you have to assume some
number for the population exposure.
The number I have given has quite a lot of remaining conser-
vatism in it, including the assumption that everybody lives within
62 miles of a nuclear power plant, which is not the case.
This is averaged throughout the U.S. population which is a
mathematically accurate thing to do, using the linear hypothesis.
But the end result is probably a meaningless number. It ranges
from an insignficant fraction to a fairly significant fraction.
Dr. Morgan. If I have done my arithmetic right, you are as-
suming the average dose would be on the order of 10"^ of a rem
(1/1, 000th of a rem, a millirem)?
Dr. Mattson. We are assuming the whole body dose is the
average for a population living within 62 miles of a reactor site.
Let me test the number, if you would give me jsut a second. Fif-
teen millirem per year is the maximum exposure. The average would
be about one millirem. There is still some conservatism in that
Dr. Morgan. I do not think so.
Dr. Mattson. I am sorry; what is your question?
Dr. Morgan. Just mental arithmetic here tells me you are as-
suming about 1 millirem per year, using the BEIR data for all types
Dr. Mattson*. No, sir, that is not the number that comes out.
Dr. Morgan. Dr. Sternglass?
Dr. Sternglass. In connection with the EPA hearings on March
10th, I prepared an estimate as to what would happen if the pro-
posed new standard of 25 millirem maximum which is now suggested
as acceptable for the maximum limit for the nuclear fuel cycle
were it to come into effect.
This is what I did. I used the figures of the BEIR Report,
3,000 to 15,000 cancer deaths annually for a dose of 5 rems over
30 years, corresponding to 167 mrem per year.
Under those conditions, the dose of 25 mrem that would be
legally allowed per year will lear to approximately 15 percent
of this number resulting in 449 to 2,245 cancer deaths per year
in the U.S. Over a period of thirty years, this is from 13,470
up to as high as 67,365 additional cancer deaths assigned to the
gneration of nuclear electric power alone, not counting all other
sources of manmade population exposure from fall-out, industrial
uses, uranium mining or things that are not going to be covered
by this 25 mrem standard.
I must add to this, this is based on the linear hypothesis
which is based largely on high dose-rate data.
If indeed the membrane effect is important, and the latest
animal studies show that the risk at low doses at low dose rates
may be ten to a hundred times greater or more than, we are ending
up with numbers that go into the hundreds of thousands.
That is why I am so concerned about a major decision without
looking into these numbers and into these low dose rate effects
more careful ly .
Dr. Morgan. Dr. Shleien, do you have a comment you would
1 i ke to make?
Dr. Shleien. Not really. It is just that we recognize, the
Department of HEW was cosponsoring the BEIR Committee, and we re-
cognize the results and use the results. We also recognize the
fact that there are other groups that have evaluated the same
problem, such as NCRP and that their opinion is quite different
from the BEIR Committee conclusions, at least in estimation of the
best available estimate and the estimation of the lower limits.
Other than that, I do not have anything to add.
Dr. Morgan. Dr. Ellett, what about EPA?
Dr. Ellett. I particularly dislike this particular numbers
game because I think you have to look at the probability for can-
cer for a given dose of radiation, and the probability of someone
receiving that dose. It is true that EPA limits, if you use a
straight multiplication with the U.S. population yield the num-
bers he indicated, but the limit is not the dose that people re-
ceive. This (the limit) is the dose, to the highly exposed people.
I can recall at least one EPA study,—' which indicated the average
dose to everyone in the United States from the nuclear power in-
dustry came out to something like half a millirem per year, a fac-
tor of 40 less than proposed limits for the U.F.C.
I am not saying that this results in a small number of health
effects, rather that you have to remember that standards are set
up for the most exposed person and do not mean that everyone in
the population is in the most exposed group. Certainly the aver-
age dose is going to be a lot lower than that to the most exposed.
A possible exception is occupational exposure where indeed
you may have people exposed up to the legal limit. This certain-
ly is not true of the average radiation worker. EPA is looking
at occupational radiation standards now, and it is very difficult
from presently available data to find out what dose the average
For an occupational group to be exposed for a lifetime at 5
rems per year, using BEIR risk estimates, it would appear that
their average life shortening (due to cancer) would be something
on the order of 3/lOths to 1/2 year, if an absolute risk model
were used and about 1.6 times greater, if a relative risk model
is used. Therefore, the average estimated life-shortening may
be up to a year for occupational hazards if you were exposed at
4 to 5 rem per year for a working lifetime. These are estimates
similar to those given in the BEIR Report.
I am not sure that the risk from 5 rem per year is even a
fair basis of comparison. It looks like 1 rem per year would
be very high for the average occupational exposure in the nuclear
industry. Our own data tell us it is like 2/1 0th of a rad per
year but we know a lot of zeroes are averaged into that data, so
that I would guess average occupational exposure might be a fac-
tor of 5 greater, i.e., 1 rem per year.
As I indicated before, the life-shortening is something on
the order of 1/2 year per radiation exposed worker at 5 rem per
year. There is no epidemiological study that I know of that
could measure this, regardless of the size of the work force ex-
You might compare radiation risk at 5 rem per year to the
risk of accidental death in industry. We have done this and it
looks like that for that fraction of the radiation workers who
receive 5 rem per year, they are up to two to four times the
average risk for all American industry.
Within any particular industry, there are people that have
high risk jobs and low risk jobs. I do not know if it is com-
pletely fair to take the highest risk for atomic workers and
compare those to an average for a particular industry. It looks
like the radiation workers have a risk somewhat comparable as to
that of an agricultural worker. Agricultural work is not a par-
ticularly safe occupation.
Dr. Morgan. Dr, Bertell?
Dr. Bertell. First of all, I do have the numbers here for
the 1974 report on workers and one rad exposure was exceeded by
5,342 workers in the power reactor and fuel processing and fab-
The average exposure of personnel in the U.S. nuclear plants
was .965, which is essentially 1 rad. I think we are talking a-
bout that exposure.
I would also like to talk to the point of an aging effect,
which, from what I gleaned you are saying, Dr. Ellett, is not the
same as life shortening. That is tricky.
Dr. Ellett. I have not discussed the aging effect. I ad-
dress only premature loss of life due to cancer.
Dr. Bertell. All right.
Dr. Ellett. I am sorry if I did not make that clear.
Dr. Morgan. Unless there is some burning desire to speak --
Dr. Bross, There was reference to the numbers game. While
it may not have been the purpose of persons who created the BEIR
Report, the fact is that the BEIR Report provides the favorite
raw materials for this kind of numbers game.
I would like to speak in terms of our test findings from
the Tri-state. In the women who were receiving radiation prior
to -- that is prior to and during pregnancy -- about a third of
all the leukemia that occurred in their children was due to rad-
iation. We can pin it down quite nicely.
I know that there are very many people who do not like num-
bers, large numbers anyway, and who do not like statistics. So
I would like to just add one other point. I have here a copy of
the correspondence dated October, 1974 dealing with exposure of
a single worker at the nuclear fuel services.
As you know, the permissible level is about 12 rem per year
emergency peak exposure and long-term exposure to age N years of
(M-18) times 5 rems.
This particular exposure is not too great. The whole body
exposure is less than 1 rem, 0.8 rem. What happened was that
this particular young man only worked for a couple of months be-
cause there was a spill apparently on his ankle. Consequently he
went over his quota, and this short period is all he worked; but
he shortly conceived a child, and then later conceived another
The two children are both victims of Holder's Syndrome a
very rare disease. This is a hereditary disease involving a re-
cessive gene which is expressed as the deficiency of a particu-
lar enzyme. As with every single case, and this is a single case,
we can never be certain, absolutely certain, in this instance
that radiation was in any way a factor or a contributing factor.
We cannot do this with one case.
That is why we have to go to larger scale studies. But I
think that what you would get from this is while the general
figures in these number games and so forth are very abstract,
they can be very real to the person who happens to get this kind
of exposure. As this young man put it, even at $3.75 an hour, it
was not worth it.
Dr. Morgan. Dr. Richmond?
Dr. Richmond. I think several comments were made about the
numbers games and it does give people on the scientific end prob-
lems from time to time.
What really is embedded in the way we get risk estimates is
the principle of commutati vity , this is, you would get the same
cancer yield, theoretically, if you had 100 rem delivered to
10,000 people as you would if you had 10-3 or a millirem deli-
vered to 1 billion people.
Obviously, this is not the case.
Dr. Sternglass. It could be an error in either direction.
Dr. Richmond. That is just the point I am getting to. It
may underestimate the situation for cases where the radiation
doses may tend to be higher than the average.
I think that this is the problem with this particular ap-
, proach because the classic example is that you cannot necessarily
change the sequence of things. The principle of commutati vity .
The best example is that it is not the same to put your shoes
on over your socks as it is to put your socks over your shoes.
An example of the numbers game I do not mean this to be
serious, but it gives you an idea of the hazards you can get in-
to. If we know the U.S. intake of aspirin today, any day, is
approxiamtely 40 tons, this is nationwide, for a 1 gram intake,
on the average, a person will lose about 1 milliliter of excess
blood from gastrointestinal bleeding. You take the aspirin be-
cause there is a risk-benefit; it does good for us.
Using the same principles that we use in the man-rem linear
hypothesis, by simple arithemetic, and assuming four liters of
blood would be lethal in one man, then this 40 ton per day would
cause 10,000 deaths per day.
And I think that there is some wise guidance in the document
I mentioned earlier, NCRP Publication 43 about the hazards invol-
ved in the misuse of the man-rem concept.
!_/ Office of Radiation Programs, Environmental Protection Agency.
Estimates of Ionizing Radiation Doses in the United States,
1960-2000. Washington, D.C. August 1972. Govt. Print Off.
The Cost-Benefit Theory of Federal Radiation Standards,
, Is It a Proper System? What are Alternative Systems?
Dr. Morgan. I will have to draw this discussion to a conclu-
sion and go to question 11.
This question is. Explain the cost-benefit theory on which
the Federal radiation standards are based. Is this a proper sys-
tem to use? Is there a better one?
I will call on Dr. Mattson to make any comments that he
wishes on cost-benefit analysis.
Dr. Mattson. I suppose we ought to start out by understand-
ing what we mean by radiation standards. If we mean the recommen-
dations of the NCRP, ICRP, Federal Radiation Council, as those re-
commendations are expressed in NRC regulations, 500 millirem, 5
rem, 170 millirem, those numbers, then Federal radiation standards
are not based on a cost-benefit analysis, not as we would define a
cost-benefit analysis today.
They were based on comparative risk to some extent. We have
heard Dr. Morgan and some others talk about trade-offs that were
made, e.g. comparing safety of workers at 5 rem versus other kinds
of hazard to other workers.
Bill Ellett talked about some work EPA has done as a risk
analysis rather than a risk-benefit analysis.
I do not know the genesis of this question. Let me just talk
for 30 seconds or so. Maybe I can get us to the point where we
want to be.
In implementing as low as reasonably achievable or as low as
practicable, the admonition of the standards recommending bodies,
the Atomic Energy Commission in about 1971-72 initiated a rule-
making hearing to define design objective values for releases of
radioactive materials in eflluents from light water reactors.
That was about the time of the National Environmental Policy
Act. They did a cost-benefit analysis pursuant to an Environmental
Impact Statement in issuing these regulations.
What those really were, were cost-effectiveness studies. They
look at additions to control equipment to reduce calculated doses
to individuals and populations. That information is a basis for
decision-making by a duly appointed authority. That decision was
made, and we speak of that today as a justified radiation standard.
Perhaps Bill Ellett would like to talk about the cost analy-
sis, the benefit analysis that was done for the now proposed uran-
ium fuel cycle standards for EPA.
Before I let him do that -- I will note that I am going to do
that -- we think that there is something broader that ought to be
considered in the setting of standards. We have touched on that,
many of us here today, I think.
Mr. Chairman, you talked about that briefly. That is a com-
parison of cross-technologies of costs and benefits.
Risks, we have talked about today. In costs, I include the
, word "risks." We are talking about cost-risk-benefit analysis,
dollars and cents in the sense of paying for control technology or
control equipment, risk in the sense of doses to individuals and
doses to population and benefits in the terms of electricity gen-
erated for the consumer or whatever other benefits.
We took a position in the EPA hearing on the fuel cycle stan-
dards, which may be the source of this question which may be mis-
understood by some people, but I think it is fairly clear how we
stated it, and that was, we have existing today radiation stan-
dards for individuals which have not unanimous but certainly wide-
spread support from the scientific community. That is, 500 milli-
rem per year and 170 millirem per year per population group as I
If those limits include the admonition to stay as low as rea-
sonably achievable below those numbers, that is basically the sys-
tem of regulation that we have.
We feel that that is a good system, that it works, and we are
keeping doses significantly below those numbers, and we agree with
the BEIR Committee in a sense that we can keep doses on the aver-
age to people in the United States below a millirem per year in
the year 2000 and we are doing it. .03, .04 millirems per year on
the average, I believe, is that number that was used this morning.
If we are going to change that system of regulation, we ought
to have a reason for changing it. We ought to know that we can
achieve greater health benefits, if you will, or that is decrease
We took a position in the EPA hearing that when the fuel cy-
cle standard was being proposed that would replace the 170 and 500
millirem by a number of 25 millirem to the whole body, it would
establish a system that achieves essentially what is being achieved
today but would require a significant spending of money in order
to achieve the new system.
We said on the basis of cost and benefits, that we did not see
any increased benefit to man. We do not think the number of health
effects could be measured, and we did see substantial cost in what
EPA was proposing.
We did not recommend promulgation of the standard, but we did
not say raise the standard that exists today, and we did not say
raise the doses that exist today. We said that what was proposed
accomplishes essentially the same thing as the already existing re-
gulations. If the standards are to be lowered, they ought to be
lowered on the basis of a showing of need to avoid unacceptable
I guess that is about all I have to say on cost-benefit.
Dr. Morgan. I have been rather pleased that members of your
staff have used a larger figure for the cost of a rem. I have
heard them use on several occasions $1,000 per rem.
We know sometimes a figure is used as low as $10 per rem. I
believe that this conservatism of NRC is to be admired. I hope it
is possible to maintain this.
Perhaps Roger, or some of the others, would like to go into
this in more detail, but for calculation purposes, for planning
purposes, we have to decide whether it is worth the investment to
clean up this radioactive gas, to reduce the occupational exposure,
to reduce the amount of radio-iodine emitted into the environment.
Do you figure the cost of bringing about these remedial changes
in the procedure? What is the meaning of this? If it costs more
than $1,000 to bring about these changes, more than $1,000 to re-
duce 1 man rem, would one pause to decide whether it is worth the
investment? If it costs less than $1,000 per rem, then can one
consider seriously making this investment to reduce exposure and
decrease the man rem?
By man rem, we mean exposure that is arrived at by taking the
number of persons in the population and multiplying it by the aver-
age dose received by that population. For the mathemetician , it
is the summation of the number of people in each exposure group
times the dose received by each group of the population.
Dr. Mattson. Yes, sir. It is important to recognize, first
of all, under our system of regulation, there are some specific
standards for the protection of individual members of the general
public living off-site of nuclear power reactors. Those numbers
are dependent upon the pathway, i.e., the way that the radiation
reaches human beings.
In the case of the liquid pathway, the number is 3 millirem
per year; in the case of a gaseous pathway, it is 5 millirem per
After an applicant for a license to operate a nuclear power
plant has shown that he can protect individuals around his site to
that degree, then we look in addition at the protection that he
provides to the population within a 50-mile radius of the site.
To do that, we look at the doses to people distributed within
that area. Those doses are summed mathemetical ly . Then in the
analysis we add equipment, according to the state of the art, for
effluent control .
If the equipment in incremental additions costs more than
$1,000 per man-rem reduction in the population exposure, then
equipment need not be added to the facility. If it costs less
than $1,000 per man-rem, the equipment must be added.
As you alluded, the value of $1,000 per man-rem reduction of
population exposure generally is considered to be conservative,
and the literature has spoken to that.
Dr. Morgan. Dr. Edsall?
Dr. Edsall. I would like to raise the question in this con-
nection of what is to be considered an acceptable risk, and it
seems to depend a great deal on the kind of thing that one is con-
The present standards for plutonium exposure must be consi-
dered in the light of the general concept of acceptable risk. K'.il.
Bair, one of the top experts in the study of plutonium effects in
animals, has estimated that about one person in eight, carrying
the "permissable" lung burden of 16 nanocuries of plutonium, might
develop a lung tumor in the course of the years, if humans are as
susceptible to plutonium as rats. If plutonium were (for instance)
a food additive, this would be considered completely unacceptable.
An advisory panel of the FDA, on food additives and pesticides,
wrote in its report: "No one would wish to introduce an agent into
a human population for which no more could be said than that it
would probably produce no more than two tumors per thousand."!/ In-
deed the panel indicated that testing ought to indicate less than
one tumor produced per million animals, if it were to be considered
satisfactory and safe. Plutonium, of course, is not a food addi-
tive or a pesticide, but a fuel and the chief ingredient of the
most deadly known weapons; but the difference in criteria for ac-
ceptability in the two cases seems to me to be glaring, and we
ought to think more deeply regarding what we should consider as
acceptable when we deal with radioactive poisons.
Dr. Morgan. Question from the audience?
Ms. Hornblower. Martha Hornblower from the Washington Post.
I wonder whether one of the officials from FDA could respond
to Dr. Edsall 's remarks on the comparability of toxic substances
standards and radiation?
Dr. Morgan. Would someone from the Bureau please comment?
Mr. Barnett. I do not think our expertise in the Bureau is
such that we are able to comment on that.
Dr. Morgan. I would like now to call on Dr. Ellett to give
the view of EPA.
Dr. Ellett. I think that Roger Mattson has given at least
one definition of the possibility of cost-benefit of balancing.
Now I would like to look at some other ways.
I suspect the best system to use depends on a particular case.
Federal Radiation guidance was based on balancing some kind of a
benefit against its costs, but included also a risk benefit bal-
ancing where it was assumed there would be a risk from radiation
and that this risk should be small compared to the benefits that
are gained from using radiation.
On the other hand, our drinking water legislation called for
levels for radioactive substances that were as low as feasible,
taking water treatment costs into consideration.
Certainly when we look at how ICRP considered occupational
79-767 O - 76 - 9
recommendations, they looked at risks in other industries to try
to achieve some kind of balance of risk against risk.
The cost-benefit theory or balancing has been recommended
really as a means of determining what is as low as readily achiev-
able. However, it may presume you have much better data than you
usually have. I think in radiation work, we are particularly for-
tunate in that we feel that we have some idea of what the benefits
are in reducing health risks as we reduce dose. Even though this
is based on arguable assumptions, you have some data on cancer and
genetic effects, and you have some idea of what, for a particular
piece of dose reducing equipment, the cost is. For other energy
sources this is not true.
I do not think that standards from the uranium fuel cycle, for
example, that EPA has proposed, that Roger Mattson refers to, can
be broadened to consider the production of energy from all alter-
nate sources of energy, for example by balancing risk and cost for
radiation exposure due to the uranium fuel cycle, as opposed to
balancing risk and health effects due to coal, oil or solar power.
We simply do not have information on what the health effects are
for all energy sources nor in large measure, do we have information
on what equipment control costs are.
Congress has addressed this question for some pollutants. In
the Air Quality Standards for example, they say air quality should
be at some margin of safety which will not show health effects. (It
is easier perhaps for a Congressman than a scientist to say what
effects occur, at what level.) But I think this illustrates there
are different ways of approaching the setting of standards.
It is very difficult to do such balancing for exposure to the
general population. We assume that health risks at 500 millirem
to an individual are so small that we should accept these; but then
look for ways to achieve a smaller dose based on some kind of ra-
tional basis on how you spend money to reduce the risk further.
I do not know what kind of balancing was done for the histor-
ical 500 millirem annual limit to individuals. I am not convinced
that scientists are any better able to evaluate what the risks from
500 millirem per year is worth in dollars than nonscientists. These
are essentially political decisions in an economic context, and
this is the sort of thing that should be subject to more consider-
ation by legislative bodies and the public in general.
We have to decide as a people as a whole, not radiation scien-
I have a little problem with a cost-benefit balancing that is
arbitrary such as $1,000 per man-rem. I feel a man-rem is equiva-
lent to so much in human life, this puts us in the very difficult
situation of assessing human life in dollars. Some have argued
that we do this every day, but I am not convinced that these argu-
ments are all that persuasive.
Dr. Morgan. I will take two more comments --
Dr. Charles. May I ask a question?
Dr. Morgan. Our program is to take one more written question
and ask for remaining questions from the floor.
Dr. Charles. This has to do with cost-benefit.
Dr. Morgan. That is fine. You can ask that.
Dr. Charles. I have something else to ask. May I say some-
thing about cost-benefit? I am a pediatrician and as I listen to
discussion about cost-benefits which is the politicians' way of say-
ing they don't want to spend money for health, I tell you for
years, I have been trying to get safe school iDuses on the American
highway. This is what I hear all the time; -- no funds available
until the public pressure builds.
We do not talk about cost-benefits when we have a tiny pre-
mature that needs thousands and thousands of dollars put into it
to save a life. I do not understand how you can equate the lives
that you are talking about today here with cost-benefits. It seems
to me to be unfair to the American people to use this kind of ana-
lysis. We did not use cost-benefit analysis in Vietnam.
Dr. Ellett. May I respond to that in part?
Dr. Morgan. Yes.
Dr. Ellett. I think it would be very easy if we could say
thousands of dollars would save a human life. Roger Mattson was
talking about something like $4 million to save a statistical hu-
man life and at that level of expenditure, society has to decide
if this is the place to spend $4 million.
These are hard decisions to reach when you are talking about
that kind of money. I think it is up to our government in the
form of our legislature and the Executive Branch and the people
as a whole to decide where is the best place to spend this money
to make life better for all of us. It is a lot of money.
Dr. Morgan. Now, we have opened up the floor -- I had in-
tended to put that last -- we will continue.
You had a question, Dr. Collins?
Dr. Collins. With respect to cost-benefits, in 1974 for
84,097 workers monitored, 88.4 percent were already below 0.5 of
a rem in that year, so what we are really looking at here is the
cost of reducing radiation for the 11.6 of workers who got above
that. In going through the data for a number of plants we
found that a considerable number of plants already comply with a
limit of 0.5 rem per year for their workers.
The improvement is needed in the bad plants, the plants such
as Kerr-McGee at Cimarron which had shocking conditions. There
are a number of other plants in the 1974 report where the situation
is bad from the standpoint of radiation exposure to workers.
In other words, there is no question that technologically re-
duction of the maximum exposure level to 0.5 rem per year is prac-
tical. It is realizable. It is not that we are calling for a re-
duction by 10^ or 10^. We are talking about something which, from
the engineering standpoint is quite feasible. It may cost some
people some money.
We would concede that it may affect the sloppy engineering
that goes on that allows a situation as in West Valley, where tran-
sient workers are called in and given a few hours exposure and then
yanked off the job. Then as we know, years later, these transients
can suffer the consequences of their exposures.
Dr. Morgan. I will take one more question from the floor.
The gentleman in the orange shirt.
Mr. Kepford. I would like to state a couple of comments with
regard to cost-benefit. I think the important thing we should
consider when talking about cost-benefits, if we must use this,
is cost to whom and benefit to whom. We have not touched on that
When we talk about the costs of installing this radiation
holdup equipment, we talk about the cost to the utility, but in
reality the utility does not pay one red cent of these. It is
added to the rate base. They earn a return on it.
Not only do they get their money back, but they earn money
on it. The cost to the utility is zero. The cost is passed on
to the rate payers. The rate payers pay the cost.
Who gets the benefit? In reality, the cost of your electri-
city is a part of the cost. You pay for that. That is not a bene-
fit. The benefits accrue to the stockholders They get more than
what they paid for when they bought the stock. They get the bene-
The real costs we are talking about are the health-costs.
Those are the ones that are important.
Now, with regard to the NRC's rules and regulations, of which
we have heard much today, at a bare minimum they are only as good
as the NRC's willingness to enforce them, and frequently in the
past, the NRC has been totally unwilling to enforce them, and I
use this one simple example: the as low as practicable guidelines.
It is only because of a court decision dated December 9, 1975
that the NRC was required by the District of Columbia Court to en-
force the as low as practicable guidelines. I will offer the
Board a copy of that decision.
Dr. Morgan. I would appreciate it. You can submit it for the
Dr. Mattson. One minute. We have to get to the last question.
First of all, on the cost-benefit criticism, we agree that those
are important considerations. In that regard, the Nuclear Regula-
tory Commission has announced its intent to hold a rule-making on
whether there are alternative ways to make these decisions. If
there are not, what is the proper value for making these cost-bene-
fit trade-offs in population exposure and reductions. That is com-
ing up in the future sometime.
I would be interested to hear your views on that.
With regard to the court decision, there is a slight nuance
to that Court decision. When Appendix I, the Design Objective for
Light Water Reactors was issued last May, there was a grace period
for reanalysis and for buying equipment for operating facilities
and for change of facilities in the design or construction process.
That grace period is up this summer. June 4th is a date that
sticks in my mind.
The AEC staff and the NRC staff, which was responsible for li-
censing actions while the rule-making was going on, made an in-
terim decision. What they did was adopt a very conservative posi-
tion, as it turned out, more conservative than the subsequent de-
cision on Appendix I.
When the decision came out, there was a question for some
plants about to go on line as to whether they needed to go through
some very sophisticated analyses required by this new regulation,
or whether they could stay in operation using the old conservative
basis, i.e., whether that was a bad rationale. They were providing
better protection, was that not good enough?
The court decision that you have referenced ties into that
very complicated legal and procedural argument about the timing
of the application of the regulation, that is all. We were en-
forcing Appendix I -- in fact, we were enforcing something more
stringent than Appendix I. We are today and will be doing so un-
til June 4th of this year when Appendix I goes into full effect.
!_/ U.S. Food and Drug Administration. Advisory Committee on
Protocols for Safety Evaluation. Panel on Carcinogenesis
Report on cancer testing in the safety evaluation of food
additives and pesticides. Toxicology and applied pharma-
cology, V. 20, Nov. 1971: 419-438.
Specific Recommendations for Congressional Hearings.
Legislation or Other Actions
Dr. Morgan. We must come now to the last question, and we
must conclude not later than 5:00 o'clock.
The last question; the staff tells me, we must ask the panel,
What recommendations do you have for specific congressional hear-
ings, legislation or other action to better protect the public and
workers from low-level radiation?
Dr. Bross. I would say in summary you have more than enough
solid, scientific evidence of the hazards of accumulated genetic
aggregation to justify immediate public health measures to protect
the American public against exposures to the low-level radiation,
particularly unnecessary low-level radiation.
In the medical area, it is now possible to reduce the expo-
sure by a factor of 10, involving such things as mandating the use
of high quality films instead of cheap industrial films which are
often used, and a lot of other technology. We have the technology
to do the job of cutting the exposure to the public from medical
x-rays by a factor of 10. There is not a lot of argument about
We are not doing it. The job for Congress is to see that this
In the nuclear power area, you have already heard several
times that the present level of radiation of 5 rems a year should
be immediately reduced and can be immediately reduced by a factor
One thing I learned, just by casual talking around the table,
that this reduction may unofficially be acceptable to several
members of the regulatory agencies. They have their own personal
views as opposed to the offical views of their agencies. There is
something in process, but it is dragging.
My third recommendation is different in character, and that
may seem like a very drastic change. In brief, what I would like
to suggest for consideration is that we should make murder by tech-
nology a criminal offense. Therefore, we should put people who do
stupid things with technology that kill other people in prison for
a couple of years. I do not think anything would do better to give
people second thoughts about whether to put these chemicals into
the environment, to put unncessary radiation into the environment
than the thought that they may go to prison for a couple of years
as chemists, as businessmen, as members of regulatory agencies,
and I think that this would have a salutory effect.
Dr. Morgan. Thank you. Next we will hear from Dr. Bertell.
Dr. Bertell. I agree with Dr. Bross. I also have a sheet of
written recommendations. Is it permissible to submit this? (See
Appendix.) I have copies for anyone else who would want one.
Pretty much they have been stated, but I think it summarizes my re-
What I would like to speak for is a change in attitude. I
think I speak for many millions of Americans, and I would like to
ask that we take a look at man and say, what can he do, what is so
wonderful about him that is as yet an untapped source, instead of
saying, how much abuse can he stand.
I would ask that when we try to assess a problem, we place
quality of life higher than GNP.
I would ask that we place a higher priority on health than on
energy. Man would be better off with less hurry, with a more con-
templative lifestyle. It is not necessary to have all of this en-
ergy. It does not improve our standard of living.
Dr. Morgan. Dr. Sternglass?
Dr. Sternglass. I would like now to point out and to recom-
mend and urge strongly that Congress mandate population studies of
the type that were recommended in 1963 by the Joint Committee, but
have never been carried out, that these should be carried out un-
der the auspices of the EPA by independent groups and universities
using the best statistical methods available, that this kind
of funding if necessary should be taken from the studies of other
types which are not so directly related to the very urgent ques-
tion of human exposure and human effects studies.
I believe that furthermore Congress should hold hearings on
the kinds of studies to be carried out on animals and large human
populations, the very low doses and dose rates, because the indi-
cations are that these are not being adequately done now. I think
Congress has a right to know before appropriating money for any
further research and development in this area whether or not our
present experience with human exposure has been adequately evalu-
ated or not.
I believe further that these studies should extend to pat-
terns of worldwide fall-out. They should extend to patterns of
health effects around various nuclear facilities and that this
should be a high priority mandated by Congress.
I think also that it would be important to investigate in Con-
gress some time why some of these effects were not investigated
earlier, why so few scientists find it possible to work in this
area without fear of losing their jobs or their grants. This en-
tire question of secrecy in this whole area has dimensions which
I think may approach those that we have only recently recognized
with regard to our intelligence agencies, the CIA and the FBI.
I am deeply concerned that many scientists who had informa-
tion that could have helped to save human lives were prevented
from publishing, prevented from bringing it out in the open, and
that this kind of investigation must be carried out because we are
going to be dealing with an agent in the environment which cannot
be seen, cannot be felt, and cannot be smelled. Unless we find a
way to solve the social problems of dealing with this source of
energy, then I believe that it cannot be used without risking our
Dr. Morgan. Thank you.
Dr. Martell. We have heard today that the BEIR Report is out
of date and also has not given consideration to certain important
questions. I recommend that among other things, we should consider
reconvening the BEIR Committee, or parts of it, to consider impor-
tant questions that have not yet been addressed.
We have, first of all, a current review of the "hot particle"
risk on which, I understand, the BEIR Committee members have mixed
reactions. They certainly are not in agreement. They must also
consider the issues raised by my "warm particle" hypothesis and by
the multiple mutation process.
If a multiple mutation process is involved, as I mentioned
before, alpha emitters become not just a contritDuting factor but
perhaps a principal agent of cell mutation and cancer. I think
that the BEIR Committee should review the evidence for and the
implications of a multiple mutation hypothesis and process. Other-
wise we will be basing important decisions for the future,
for future generations, -- on a linear hypothesis which has so
many shortcomings that it is befuddling.
Finally, I suggest that it is overdue that the BEIR Commit-
tee and others consider the microdistribution of internal emitters
in the gonads with emphasis on, but not restricted to, alpha emit-
ters. And they should specifically look in the sperm and ova, be-
cause we already have an indication that there may be more polon-
ium and Plutonium at these critical sites. Let us find out. The
second area that has been bothering me became more evident today.
It seems that the emphasis on cancer research in this country has
been restricted to chemicals and virus as agents, with no adequate
attention to radiation for which there is no question of human mu-
tagenic and carcinogenic effects. It seems to me that this area
deserves far more than a few percent or less of the cancer research
effort of this country.
In this connection, I suggest that it is long overdue that
the National Cancer Institute establish a substantial program of
radiation-induced cancer research. Within such a program there
should be a high-priority given to the study of the micro-distri-
bution of the internal alpha emitters at the tumor sites in high
risk groups. (See Appendix.)
Dr. Morgan. Dr. Ellett, did you have a comment?
Dr. Ellett. No.
Dr. Morgan. We have one or two more minutes yet before we
Dr. Caldicott. My recommendations are (1) that medical ex-
posure should be reduced, that there should be a requirement that
the dose of radiation of the x-ray should be written on the x-ray
so summation of radiation dose to each person can be tabulated.
(2) There should be an official Congressional hearing on the
medical dangers of proceeding with nuclear power. (3) There
should be an offical policy to educate the public on the genetic
mechanisms and consequences o'*' radiation -- the risk benefit fac-
tor -- presently the governments of the world are spending mil-
lions of dollars to find a cure to cancer, leukemia and congeni-
tal diseas. Yet the same governments are spending billions of dol-
lars on the nuclear industry and nuclear weapons which will direct-
ly lead to proliferation of these diseases.
(4) I would recommend that we stop all nuclear power devel-
opment until and whenever we can prove it is safe. (5) I would
also recommend that we stop this country and others from exporting
nuclear power plants, which will lead directly to proliferation of
nuclear weapons which threatens the future of life on earth.
Dr. Morgan. I would recognize the gentleman.
Dr. Charles. I want to conclude by saying as a citizen of
New Jersey and New Jersey having the distinguished position of
unquestionably having the highest cancer rate in the country today,
I can tell you that we are very frightened.
As a representative of the medical profession and citizenry
there, we are disturbed with the plan to put new nuclear reactors
in Atlantic City, a plant that has been designated as a first-gen-
eration technology. We do not know of any reassurances from the
regulatory agencies which will allow our people to live in any
kind of peace and safety.
I ask, therefore, seconding what Dr. Caldicott has said, that
there be a moratorium on further nuclear reactors, in New Jersey
especially, because we have had enough cancer, until you can come
up with the answers that obviously are not evident here today and
enough agreement about the need for further research. We do not
want to be statistics.
Dr. Morgan. I would like to thank the panelists and the
audience for their perseverance and their participation in this
discussion here. I declare the meeting adjourned.
(Whereupon, at 5:00 p.m. the conference adjourned.)
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GLOSSARY OF RADIATION HEALTH TERMS*
Aging Effect: The theory that radiation produces an acceleration in
the aging process.
Alpha Particle: A charged particle which has a mass and charge equal
in magnitude to a helium-4 nucleus and is emitted from the
nucleus of an atom.
Alpha Rays: Alpha particles emitted by radioactive elements.
Background Radiation: Ionizing radiation present in the area of
interest and coming from sources other than that of primary
BEIR Report: A report prepared by the Advisory Committee on the
Biological Effects of Ionizing Radiation, Division of Medical
Sciences, National Research Council of the National Academy
of Sciences. The report is entitled "The Effects on Populations
of Exposure to Low Levels of Ionizing Radiation."
Bioassay: The determination of the effect and/or strength of a sub-
stance by administering it to one test organism and a standard
preparation to another test organism and then comparing the rela-
Body Burden: The total quantity of a radionuclide present in the body.
Bone Seeker: Any substance which migrates, in vivo, preferentially
BRH: Bureau of Radiological Health of the Food and Drug Administra-
tion, U.S. Department of Health, Education, and Welfare.
Cell Sterility: The inability of a cell to reproduce.
Chronic Exposure: Radiation exposure of long duration by fractiona-
tion or protraction.
Congenital: Existing at or dating from the time of birth.
Cosmic Rays: Strongly penetrating rays which come from beyond the
Earth's atmosphere and contain particles which move at ex-
tremely high speed.
Curie: The special unit of activity. One curie equals 3.7 x 10-^*-*
disintegrations per second.
Cytology: A branch of biology which deals with the structure, function,
multiplication, pathology, and life history of cells.
These definitions are adapted from a variety of sources.
Deleterious: Hurtful, noxious.
DNA: The abbreviation for deoxyr ibonuc leac acid which is a nucleic
acid found especially in the cell nucleus and is thought to be
the genetic material.
Dose Rate: Absorbed dose delivered per unit time.
EPA: Environmental Protection Agency.
Epidemiology: A science that deals with the study of epidemics by
observing the incidence, distribution, and control of disease
in a population.
Extrapolate: To project, extend, or expand known data or experience
into an area not known or experienced in order to arrive at a
new, conjectural knowledge of the unknown area by inferences
based on an assumed continuity, correspondence, or other paral-
lelism between it and what is known.
Gamma: A unit of magnetic field intensity equal to ten oersteds.
Gamma Radiation: Electromagnetic radiation emitted in the process of
nuclear transition or particle annihilation.
Gamma Ray: Short wavelength electromagnetic radiation of nuclear ori-
gin (range of energy from 10 KeV to 9 MeV) emitted from the
nuc leus .
Genetic: Relating to the germ cells which contain the genes that deter-
mine the characteristics of the offspring.
Geomagnetic: Of or relating to terrestial magnetism.
Health Physics: The application of the science of physics (and here -
radiation physics) to health problems.
Homeostasis: A relatively stable state of equilibrium or a tendency
toward such a state between the different but interdependent
elements of a group.
Hot Particle Controversy: The disagreement about the relative car-
cinogenicity of various sizes of particles of plutonium when
inhaled into the lung.
ICRP : International Commission on Radiological Protection.
Internal Emitters: Radioactive substances which emit radioactivity
when taken inside the body.
Interpolate: To estimate the values of a function between two known
In Utero: Before the time ot birth; while in the mother's
Iodine : A radioactive form of iodine.
Ionizing Radiation: Any electromagnetic or particulate radia-
tion capable of producing ions, directly or indirectly,
in its passage through matter.
Kilorad : 1 ,000 rads .
Linear Energy Transfer (LET): The average energy locally imparted
to a medium by a charged particle of specified energy per
unit distance traversed.
Linear Hypothesis: The assumption that a dose-effect curve derived
from data in the high dose and high dose-rate ranges may be
extrapolated through the low dose and low dose range to zero,
implying that, theoretically, any amounts of radiation will
cause some damage.
Lymphatic System: A tubular system supplementing the blood vascular
system of vertebrates; it collects lymph from the tissue spaces
and returns it to the venous circulation; it is located in the
spleen, lymph nodes, thymus, and tonsils.
Mammography: A radiologic technique now widely used to aid in the
diagnosis of breast cancer.
MESA: Mine Enforcement Safety Administration.
Microcurie: One millionth of a curie (3.7 x 10'^ disintegrations per
Millirad: One thousandth of a rad.
Millirem: One thousandth of a rem.
MIT: Massachusetts Institute of Technology.
NCRP: National Council on Radiation Protection and Measurements.
NIOSH: National Institute of Occupational Safety and Health.
Nonionizing Radiation: Any electromagnetic or particulate radiation
which does not contain enough energy per unit to produce ions
in its passage through matter.
NOX: Any one of a group of oxides of nitrogen.
NRC : Nuclear Regulatory Commission.
Organ Burden: The total quantity of a radionuclide present in an organ.
OSHA: Occupational Safety and Health Administration.
Overkill: To obliterate a target with more force than required.
Particulate: Minute separate particles.
Picocurie: One millionth of a microcurie (3.7 x 10~^ disintegrations
per second ) .
Rad : The special unit of adsorbed dose. One rad equals 100 ergs/gram.
Radioisotopes: Radionuclides having the same atomic number but dif-
ferent mass numbers.
Radionuclide: A radioactive species of atom characterized by its mass
number, atomic number, and energy state of the nucleus, provided
that the mean life in that state is long enough to be observable.
Radium: An intensely radioactive shining white metallic element that
resembles barium chemically, occurs in combination in minute
quantities in minerals, emits alpha particles and gamma rays to
form radon, and is used chiefly in luminous materials and in the
treatment of cancer.
Rem: The special unit of dose equivalent. The dose equivalent in rems
is numerically equal to the absorbed dose in rads multiplied by
the quality factor, and any other necessary modifying factors.
Sarcoma: A malignant neoplasma (tumor) arising in tissue of mesodermal
origin (connective tissue, bone, cartilage, or striated muscle).
Somatic: Not destined to become a germ cell; not genetic.
SOX: Any one of a group of oxides of sulfur.
Synergistic: Having the capacity to act in a cooperative action of
discrete agencies such that the total effect is greater than the
sum of the effects taken seperately.
Transuranium Elements: Elements which have a higher atomic number
than uranium; they are all radioactive; example, plutonium.
Ultrasound: Vibrations with the same physical nature as sound but with
frequencies above the range of human hearing.
WASH 740 Report: A 1957 Atomic Energy Commission report which concluded
that a major release of radioactivity from a small reactor could
kill or injure thousands of persons.
Zero Release: The prohibition of the release of any radioactive materials
from a particular nuclear plant.
Addition to the Testimo ny of Dr. Vi ctor E. Archer. M.D. from a
Letter to Mr. Bruce Myles. April 1, 1976 .
Even though natural ionizing radiation has probably
played a useful role in the evolutionary history of man, it must
now be regarded as potentially harmful to man. The reason for this
is that man has so insulated himself from the forces of nature
that a philosophy of "survival of the fittest" is much less appli-
cable to man than to other species. Consequently, even small
amounts of radiation, through induction of malignant disease and
genetic effects, must be considered to have potentially deleterious
effects on man. The linear extrapolation of carcinogenesis and
genetic injury from higher levels to the zero dose - zero response
point seems to offer the most reasonable quantitative approach to
the problem. This is the approach used by most standard setting
bodies. There is some evidence that this model may overestimate
the damage from X- and Gamma rays, but there is no evidence that
it overestimates the damage from particles having high linear
transfer of energy (LET) such as alpha particles and neutrons.
There are suggestions that it may underestimate such injury.
Even though I am convinced that "all radiation is harmful"
to man, I am not certain that this justifies the banning of nucle-
ar power or any other beneficial use of radiation. At low levels
the amount of harm is very small and has little significance to
individuals. Since our society, as a whole, is willing to accept
the well known risks associated with automobile driving, with
dangerous sports, with tobacco smoking, with alcohol consumption,
and with fire hazards in many types of buildings, it is my
feeling that our society would be willing to accept a small risk
from nuclear power. The main reason, I think, for public alarm
over the hazards of nuclear power is that for most, it is still
a new and poorly defined hazard. New and poorly defined hazards
are always much more frightening than familiar hazards - ones
that we have learned to live with.
Addition to the Testimony of Dr. Edward A. Martell, Unresolved Health Effects
Of Internal Alpha Emitters
Before the acceptability of nuclear energy can be judged, there must be an
adequate evaluation of the associated health risks. Unfortunately neither the
AEC nor our health agencies have addressed themselves adequately to the assess-
ment of the chronic health effects of Internal alpha emitters in man. It is well
established that alpha emitters are effective agents of cell mutation and cancer.
The critical, unresolved questions are: to what extent are internal alpha emitters
contributing to the general incidence of each of the serious chronic health effects
in man: cancer, heart disease and stroke, genetic effects, sclerotic disorders,
The possibility that insoluble alpha emitting particles may play a major role
in the general incidence of human cancer is supported by the growing evidence
that lung cancer in cigarette smokers is induced by alpha radiation. The measured
concentrations of radioactive lead-210 and poloniuTn-210 at the bronchial tumor
sites of cigarette smokers range up to thousands of times that found in non-smokers
(1) . Although only fractions of a picocurie of polonium-210 alpha activity are
involved, the local alpha radiation intensity at the cellular level ranges from
thousands to hundreds of thousands times natural levels. In a recent article (2)
I proposed that the induction of cancer by alpha radiation is likely to involve a
multiple mutation process and, thus, insoluble alpha emitting particles of moderate
activity (i.e., "warm" particles) which persist in tissue can be very effective
agents of cancer. A T^.ultiple nutation process of alpha radiation induced cancer
is consistent with both the age distribution of cancer and the observed higher
incidence of cancer per rad for spaced alpha irradiation exposure (2). It is
disturbing to note that for cancer i-duction by a multiple r-utation process it
is highly unconservative to extrapolate linearly to low doses. On this basis,
exceedingly sniall organ burdens of insoluble alpha emitters would be equated with
significant tumor risks. If insoluble alpha emitting saoke particles prove to be
the agent of cancer in smokers, then insoluble alpha emitting from other sources
including fallout plutonium are likely to be contributing significantly to the
rising general incidence of cancer in non-smokers.
iSponsored by the National Science Foundation.
The magnitude of the contribution of internal alpha emitters to spontaneous
mutations and genetic effects in man is also a serious neglected question. The
Subcommittee on Genetic Effects of the National Academy of Sciences Advisory
Committee on the Biological Effects of Ionizing Radiations concluded (3) that the
genetically significant exposure of man from nuclear pollutants is now very small
relative to that from natural background radiation which, in turn, is considered
to be of minor inportance comp;^red to non-radioactive mutagens. This assessment
is based on X-ray effects on mice and on other considerations which render these
conclusions applicable only to the X-ray and gar,.?ia ray ccniponr-nt of human genetic
effects. Recent studies have shov-n higher concentrations of plutoniura in human
gonads and lymph nodes than in other soft tissue organs. And there is published
evidence that both plutoniura and polonium-210 in the testes are distributed in a
manner which gives a much higher dose to the sperm than to the testes as a whole.
Thus there is basis for suggesting that internal alpha emitters rather than un-
identified non-radioactive mutagens may F.ake the major contribution to the current
spont«r.eoiis r utaticn rate in iran.
The acceptability of nuclear er.ergy will remain in doubt until we resolve
these disturbing questions regarding cancer risks and genetic effects of internal
alpha emitters. The microdistribution of alpha emitters in the gonads and at the
iiiiportant tuinor sites can be determined with experimental techniques now available.
Studies of the alpha activity burden and distribution at the turaor sites in high
risk exposure groups also would provide a reasonable test of the multiple mutation
hypothesis and its serioijs i'r.plications . Such studies nust be carried out before
we are con uitted to further proliferation of nuclear energy. To co olhf ri,'ise would
be reckless ard irresponsible and would pose a serious threat to the health and well-
being of future gontf ations.
To rf'.ody the situat ion, the following courses of action are recommended:
1. Reconvene the NAS-BEIR Conaittee for tlie purpose of considering:
(a) the "wann particle" hypothesis of aloha radiation induced cancer
(b) the evidence for a multiple mutation process of csncer induction
and its inplications
(c) the microdistribution of alpha ei^itters and othtrr radioisotopes in
the gonads and their genetic effects.
2. Establish a program of radiation induced cancer research under the
auspices of the Departricnt of Health, Education and Welfare.
3. Organize a high priority research effort to assess the mlcrodistribution
of internal alpha emitters at the tumor sites of high cancer risk groups,
to determine the burden and distribution of radioisotopes in human gonads,
and to evaluate the conceiitration of radioisotopes on effluent particles
of respirable size for selected industrial and environmental sources.
4. Defer further proliferation of nuclear energy until there is an adequate
appreciation of the chronic health effects of radiation, with special
emphasis on internal alpha emitters.
1. Radford, E.P. and E.A. Martell, "Polonium-210 : lead-210 ratios as an
index of residence times of insoluble particles tir.es from cigarette
smoke in bronchial epithelium". Proceedi ngs of t he Fourt h In ternational
S^-TTiposium on Inhaled Parti cles and Vapo urs, Edinburgh, 22-26 September
1975, Perga:,on Press Ltd.
2. Martell, E.A., "Tobacco radioactivity and cancer in smokers", American
Scie^irt^ist, 63, 404-412, July-August 1975.
3. National Academy of Sciences Advisory Committee on the Biological Effects
of Ionizing Radiations, "The effects on populations of exposure to low
levels of ionizing radiation", (BEIR Report), NAS-NRC, November 1972,
Washington, D.C. 20006
Submitted to the Record by Dr. Rosalie Bertell, Recommendations Made to the
Environmental Study Conference
'.Hiereis, In thp past ^-'e h=jve frilled to recofnlze the fact that ion-
jzinp radiation has different bioloplcal effects relative to dose,
dose rate, and to the susceptibility of the person exposed, and
v.'hereas this error has caused serious under-estlmation of the long
tern effects of radiation pollution of the environment, I propose:
AN II-fl-IEDI^TE MORATORIUM ON THE BUILDING OF FISSION REACTORS;
REALLOCATIOM OF THE MONEY BUDGETTED FOR RESEARCH ON THE BREEDER
REACTOR TO RESE^VRCH OF MORE FEASIBLE ENERGY TECHNOLOGIES;
GR'^UAL REPL\CEffENT OF PRESENT NUCLEAR REACTORS '/ITH LOCALIZED
RENE'/ABLE SOURCES OF ENERGY COMPATIBLE WITH HUMAI^ LIFE;
REFUSAL TO EXPORT NUCLE.AR TECHNOLOGY; REFUSAL TO FURTHER POLLUTE
THE ENVIRONf-IENT OF THE UNITED STATES BY REPROCESSING FUEL FOR
IMT^DIATE ATTENTION TO THE LONG RANGE PROBLEMS OF STORAGE OF THE
NUCLEAR -.rASTE ALRE.ADY GENERATED BY THIS INDUSTRY;
REDUCTION OF THE PRESENT M.AXII^JM PERMISSIBLE LEVELS OF RADIATION
EXPOSURE BY AT LEAST A FACTOR OF 10; REDUCTION OF THE LEVEL OF
PERMISSIBLE EXPOSURE FOR THE THYROID GL/UD BY AT LEAST A FACTOR OF 30.
^Tnereas our present methods of collecting health related data are
inadequate for protecting either employees or the general public
against long term chronic or lethal effects of environmental
pollution, I propose:
EMPLOYEE'S HEALTH RECORDS EE MAINTAINED FOR AT LEAST hO YEARS, ATJD
BE MOVED WITH THE EMPLOYEE IN CASE OF JOB CHANGE.
EMPLOYEE'S HEALTH RECORDS INCLUDE NON-DEBILITATING CHRONIC ILLNESS
(V'lTH DATE OF ONSET), AND MEDICAL HISTORY OF OFF-SPRING;
\/ORKMAN'S COMPENSATION LVrS BE REDESIGNED TO COVER LONG TERM CHRONIC
DISEASES, THOSE 'miCH OCCUR h TO hO YE.ARS AFTER EXPOSURE (LEUKEMIA,
OTHEr. CANCER), AND DISEASE AND INJURY TO THE OFF-SPRING CAUSED BY
OCCUPATIONAL EXPOSURES. THIS COULD BE DONE ON A PARTIAL PAYMENT
BASIS PROPORTIONAL TO THE PROBABILITY THAT THE DISEASE WAS ''ORK-
INDIVIDUAL CUr^IULATIVE RECORDS OF ALL f'lEDICAL AND DENT.AL X-RAY EX-
POSURE BE MANDATORY FOR THE GENERAL PUBLIC;
A NATIONAL EFFORT BE MADE TO REDUCE EXPOSURE TO MEDICAL DIAGNOSTIC
X-P\Y BY 50f - ELIMINATE MANDATORY X-RAY POLICIES AND MASS X-RAY
SCREE;:ING PPOGRAJ^S; reduce PRESSURES TO X-PAY BECAUSE OF MALPRACTICE
SUITES; REQUIRE CLEAR RESONS FOR EACH X-RAY AND PATIENT INFORJfED
A NATIONAL DATA BANK FOR OCCUPATIONAL DISEASES EE EST^LISHED;
A NATIONAL DATA E ANK FOR ENVIRONrffiMT \L DISEASES BE ESTABLISHED;
P.OCOGNITION OF COI^LICT OF INTEREST AS A PnOBLE'I FOR LEGISLATORS IN
SEEKING SCIENTIFIC ADVICE, FOR -JX AMPLE, IT IS INAPPROPRIATE FOR
LEGISLATORS TO SEEK ADVICE ON A PUBLIC HE\LTH ISSUE FROM UNION
CARBIDE O.AK RIDGE NUCLEAR LABOR \TORY, '..fHEN THE ISSUE IS RADIATION.
V/here^s the use of ^idvertisinp techniques on the part of the nuclear
industry and government agencies in the promotion of the nuclear
industry has confused scientific questions and misled the public,
I propose that:
THE NUCLEAR INDUSTRY REFRAIN FROM CLAIMING TO BE A "CLEAN, SAFE
AND EFFICIENT SOURCE OF ENE^.GY" ;
NF'.fS RELEASES BY GOVERNMENT AGENCIES AITO BY THE NUCLEAR INDUSTRY
BE COriFORMED TO KNOVN SCIENTIFIC FACT, FOR EXAf^PLE, ALTHOUGH THERE
IS UNIVERSAL AGREE^IENT THAT ALL EXPOSURE TO IONIZING RADIATION MAY
BE CONSIDERED HARMFUL FOR MAI^I, IT IS TIOT AT ALL UNUSUAL FOR ABNOR
MAL, OFF-SITE R.ADIATION RELEASES FROM NUCLE.AR GENERATORS TO BE
REPORTED AS POSING NO D \NGSR TO PERSONS IN THE SURROUNDING AREA.
'/hereas all of the above problems seem to stem from our basic orien-
tation tovard economic gain rather than human progress, tov'ard
v/ealth and pov/er instead of health and vrell-being, I propose that
ATTEMPT TO RESTORE A BALANCE BET'.'EEN THE NATIONAL NEED FOR ffE.ANING-
FUL JOBS AND JOB SATISFICTION AND RISING PRESSURES TO REPLACE MAN
'^ITJI MACHINES, INCREASE SKILLS DEMANDED BY COMPLICATED TECHNOLOGY
AND LIMIT THE l^ORKFORCE BECAUSE OF THE HIGHLY TOXIC NATURE OF THE
MATERIALS USED IN PRODUCTION;
PROMOTE PESEIRCH INTO MAN'S UNIQUE ^ILITY TO IMPROVE HIS STA^IDARD
OF LIVING THROUGH COOTEMPLATION AND A LESS FR.WTIC (ENERGY CONSUMING
EXPLORE CRE\TIVE CONSERVATION fE\SURES, AND 'FAYS OF REDUCING ENERGY
DEMANDS AT PE^: TIMES;
AVOID PROBLEM SOLVING IN TERIIS OF COST-BENEFIT, 'THEN THE COST IS
IN HU;-UN STRESS AND '-.'ELL-BEING AND THE BENEFIT IS LARGELY TECH-
NOLOGICAL AND ECONOMIC; RESIST THE GRC'ING TENDENCY TO REG.^RD
HAM A3 AN EXPENDABLE BIOLOGICAL RESOURCE TO BE SACRIFICED TO
FAriLIT\TE LOBBYING A.ND PROVIDE ACCESS TO LEGISLATORS FOR UNFUNDED
CI'^IZEW GROUPS TO NARROW THE POUER GAP BETWEEN THESE GROUPS AIID -
THE _ATOmC INDUSTRIAL FORUM.
UNIVERSITY OF FLORIDA
University of Pittsburgh
fACULTY OF Afo;, AM) .cuNci s May 10, 1976
DcpaitmenI of Physics
Congressman Richard L. Ottinger
Environmental Study Conference
2456 Rayburn House Office Building
Washington, DC 20515
Dear Congressman Ottinger:
I am very sorry that I was unable to be present at your conference
on May 4. I was down with a virus and had a high fever; in fact I am
still not very well recovered from it. I hope the message I called in
was delivered and there were no bad consequences from my absence.
Since I was unable to attend, there is one point I would like to
make in writing here. As far as I am concerned, it is the most important
point about the'whole conference. That is — your group of "experts" were
mostly not experts; in other words, if you are seeking authoritative
information, you had the wrong group.
We are fortunate in having prestigeous groups available to study
biological effects of radiation -- ICRP, NCRP, the UN committee, the National
Academy of Sciences Committee, the British Medical Research Council, etc.
The true experts sit on these committees. All of these committees agree
rather well on the issues; from your viewpoint, the differences among them
But your group of "experts" at the May 4 meeting were not representative
of these groups. The NCRP has about 70 members, and including past members
they form a group of about 150 who are the true experts. Yet only about
1/4 of the members of your panel are among these 150. Effects of low-level
radiation are estimated principally from animal studies but there is not a
single member of your panel who has ever done such animal studies.
I therefore believe that any information obtained from that
conference is highly suspicious. If you really want information, you
should call in the experts.
Sincerely yours ,
Bernard L. Cohen
PITTSBURGH, PA T5?60 -135-